S.B. BHATTACHARJEE MEMORIAL TRUST FOR CHILDREN EDUCATION ,DIGBOI vs. ACIT, CIRCLE-1, DIBRUGARH, DIBRUGARH

In the result, the appeal of the assessee is allowed

Bench: Shri Manomohan Das & Shri Rakesh Mishra

loss of Rs. 1,07,491/- during the year under consideration, the ld. Addl. CIT(A) ought to have hold that in any view of the matter, the ld. A0 was not justified in arbitrarily and whimsically assessing the total income of the appellant at Rs. 87,13,857/- and determining the total tax liability of the appellant

SMT. MAYA RANI DEY,DHARMANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SILCHAR, SILCHAR

In the result, appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Manish Borad, Hon’Blei.T.A. No. 120/Gty/2011 Block Year: 01/04/1989 To 08/12/1999 Shri Subhash Chandra Dey Assistant Commissioner Of Office-Tilla Vs Income Tax, Circle-Silchar Dharmanagar -799250 Tripura [Pan: Acrpd1916F] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

losses brought forward from the previous year under Chapter VI or unabsorbed depreciation under Sub-section of Section 32 shall not be set off against the undisclosed income determined in the block assessment under this chapter, but may be carried forward for being set off in the regular assessments. 9. Expounding the scope of the block assessment and inclusion

SHRI ASHISH KUMAR DEY,DHARMANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-SILCHAR, SILCHAR

In the result, appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Manish Borad, Hon’Blei.T.A. No. 120/Gty/2011 Block Year: 01/04/1989 To 08/12/1999 Shri Subhash Chandra Dey Assistant Commissioner Of Office-Tilla Vs Income Tax, Circle-Silchar Dharmanagar -799250 Tripura [Pan: Acrpd1916F] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

losses brought forward from the previous year under Chapter VI or unabsorbed depreciation under Sub-section of Section 32 shall not be set off against the undisclosed income determined in the block assessment under this chapter, but may be carried forward for being set off in the regular assessments. 9. Expounding the scope of the block assessment and inclusion

SHRI SUBHASH CHANDRA DEY,DHARMANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- SILCHAR, SILCHAR

In the result, appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Manish Borad, Hon’Blei.T.A. No. 120/Gty/2011 Block Year: 01/04/1989 To 08/12/1999 Shri Subhash Chandra Dey Assistant Commissioner Of Office-Tilla Vs Income Tax, Circle-Silchar Dharmanagar -799250 Tripura [Pan: Acrpd1916F] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

losses brought forward from the previous year under Chapter VI or unabsorbed depreciation under Sub-section of Section 32 shall not be set off against the undisclosed income determined in the block assessment under this chapter, but may be carried forward for being set off in the regular assessments. 9. Expounding the scope of the block assessment and inclusion

MAYURPLY INDUSTRIES PVT LTD.,HOOGHLY, WEST BENGAL vs. ACIT, CIRCLE 3, GUWAHATI, ASSAM

In the result IT(SS)A Nos

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

condone the delay by admitting the appeals for adjudication. We shall first take up IT(SS)A 1/GTY/2024 for A.Y. 2010-11. IT(SS)A 1/GTY/2024 for A.Y. 2010-11 03. First, we would take up ITA(SS)A No.1/GTY/2024 for A.Y. 2010-11. At the outset, the ld. Counsel for the assessee raised legal issue challenging the jurisdiction

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI vs. ABCI INFRASTRUCTURES PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which

ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI

In the result, the appeal of the assessee for Assessment Year

Bench: Sri Rajpal Yadav(Kz) & Dr. Manish Borad

setting forth such other particulars as may be prescribed and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; (b) assess or reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which

DCIT, CENTRAL CIRCLE-1, GUWAHATI vs. POTENCIAL VINCOM (P) LTD.,, KOLKATA

In the result, all the appeals filed by the revenue are dismissed and the cross objections by the assessee are allowed

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 80/Gty/2023 Assessment Year: 2010-11 Deputy Commissioner Of Income M/S. Potential Vincom Tax, Circle-1, Guwahati Vs Private Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 22/Gty/2023 Assessment Year: 2010-11 M/S. Potential Vincom Private Deputy Commissioner Of Income Vs Tax, Central Circle-1, Guwahati Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

condone the delay and admit the appeals for adjudication. 6. As the issues involved in all these appeals are identical and inter- related, the same were heard together and are being disposed off by way of this commons order. First of all we shall adjudicate ITA No. 83/Gau/2023 & C.O. No. 24/GTY/2023 AY 2011-12 as lead case. 7. The only

DCIT, CENTRAL CIRCLE-1, GUWAHATIU vs. MANOHAR MERCHANTS (P) LTD.,, KOLKATA

In the result, all the appeals filed by the revenue are dismissed and the cross objections by the assessee are allowed

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 80/Gty/2023 Assessment Year: 2010-11 Deputy Commissioner Of Income M/S. Potential Vincom Tax, Circle-1, Guwahati Vs Private Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 22/Gty/2023 Assessment Year: 2010-11 M/S. Potential Vincom Private Deputy Commissioner Of Income Vs Tax, Central Circle-1, Guwahati Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

condone the delay and admit the appeals for adjudication. 6. As the issues involved in all these appeals are identical and inter- related, the same were heard together and are being disposed off by way of this commons order. First of all we shall adjudicate ITA No. 83/Gau/2023 & C.O. No. 24/GTY/2023 AY 2011-12 as lead case. 7. The only

DCIT, CENTRAL CIRCLE-1, GUWAHATI vs. POTENCIAL VINCOM (P) LTD.,, KOLKATA

In the result, all the appeals filed by the revenue are dismissed and the cross objections by the assessee are allowed

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 80/Gty/2023 Assessment Year: 2010-11 Deputy Commissioner Of Income M/S. Potential Vincom Tax, Circle-1, Guwahati Vs Private Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 22/Gty/2023 Assessment Year: 2010-11 M/S. Potential Vincom Private Deputy Commissioner Of Income Vs Tax, Central Circle-1, Guwahati Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

condone the delay and admit the appeals for adjudication. 6. As the issues involved in all these appeals are identical and inter- related, the same were heard together and are being disposed off by way of this commons order. First of all we shall adjudicate ITA No. 83/Gau/2023 & C.O. No. 24/GTY/2023 AY 2011-12 as lead case. 7. The only

A.C.I.T., CIRCLE -1, GUWAHATI vs. M/S. SEEMA HOLDING PVT. LTD., KOLKATA

In the result, all the appeals filed by the revenue are dismissed and the cross objections by the assessee are allowed

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 80/Gty/2023 Assessment Year: 2010-11 Deputy Commissioner Of Income M/S. Potential Vincom Tax, Circle-1, Guwahati Vs Private Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) C.O. No. 22/Gty/2023 Assessment Year: 2010-11 M/S. Potential Vincom Private Deputy Commissioner Of Income Vs Tax, Central Circle-1, Guwahati Limited 5/1, 3Rd Floor Clive Row Kolkata - 700001 [Pan : Aaecp7667D] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

condone the delay and admit the appeals for adjudication. 6. As the issues involved in all these appeals are identical and inter- related, the same were heard together and are being disposed off by way of this commons order. First of all we shall adjudicate ITA No. 83/Gau/2023 & C.O. No. 24/GTY/2023 AY 2011-12 as lead case. 7. The only

S.M. LIME INDUSTRIES,GUWAHATI,ASSAM vs. DCIT/ACIT, CIR-1, GUWAHATI

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Manomohan Dasआयकर अपील सं. / Ita No.37/Gty/2024 िनधा"रण वष" / Assessment Year: 2018-19

delay was condoned. Thereafter, even though the assessee has claimed to have furnished all the details but ld.CIT(A) has summarily dismissed the appeal by observing that the submissions made are all well considered but since the assessee failed to discharge the 4 S.M. lime Industries onus on it to satisfy all the three ingredients of section

SOTAI TEA COMPANY PVT. LTD.,SOTAI, JORHAT, ASSAM vs. INCOME TAX OFFICER, WARD-4, JORHAT, JORHAT

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI LAXMI PRASAD SAHU (Accountant Member)

loss and was under no obligation to pay any tax for the relevant assessment year. 4. That the Learned CIT(A) has failed to appreciate that although an Intimation under Section 143(1) of the Act was issued on 22.08.2007, the same was passed in a mechanical and cryptic manner, without disclosing any computation, basis, or reasoning