DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 03, GUWAHATI vs. NUMALIGARH REFINERY LIMITED, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

M/S. NUMALIGARH REFINERY LTD.,GUWAHATI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. M/S. NUMALIGARH REFINERY LTD., GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI vs. M/S. NUMALIGARH REFINERY LTD., GUWAHATI

In the result, appeals of the assessee in I

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am Assessee`S Appeals

202/- Ground No.(2) for the Assessment Year 2013-14; Rs. 7,35,87,056/- (9). Disallowance of claims of deduction under the head 'Provision for Doubtful Debt' Ground and Assessment Year Amount Ground No.(2 ) for the Assessment Year 2009-10 ; Rs. 13,97,827/- (10). Disallowance of claims of deduction of 'Prior period Depreciation'. Ground and Assessment Year

JYOTI PRAKASH DAS,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2017-18 Jyoti Prakash Das Dcit, Circle-3, Guwahati Kumud Enclave, Nawaram Vs. Kakati Path, Rehabari, Guwahati-781008. Pan: Ajipd 5193 Q (Appellant) (Respondent) Present For: Appellant By : Shri Ramesh Goenka, Advocate Respondent By : Shri Arun Bhowmick, Jcit Date Of Hearing : 31.08.2023 Date Of Pronouncement : 31.08.2023 O R D E R Per Sonjoy Sarma, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.02.2020 Of Ld. Cit(A), Guwahati-2 Passed U/S 250 Of The Income Tax Act [Hereinafter Referred To As The ‘Act’]. The Assessee Has Raised The Following Grounds Of Appeal: “1(A). That Neither The Learned Assessing Officer Was Justified In Making Disallowance Of Rs. 1,43,73,603/- On Account Of Proportionate Direct Expenses & Adding The Same In The Closing Stock Of The Appellant Nor The Learned Cit(A) Was Justified In Confirming The Aforesaid Disallowance/Addition.

disallow 20% of the payments made u/s 40A(3) in the process of assessment. We, therefore, delete the addition of Rs.17,90,571/- and ground no.1 is decided in favour of the assessee. CIT vs Crescent Export Syndicate in ITA No. 202 of 2008 dated 30.7.2008 - Jurisdictional High Court decision. "It also appears that the purchases have been held

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH. vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

OIL INDIA LTD.,DIBRUGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, RANGE -2, DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, DIBRUGARH vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, DIBRUGARH vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

OIL INDIA LTD.,,DIBRUGARH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH.

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

OIL INDIA LTD.,DIBRUGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -2, DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2,, DIBRUGARH. vs. OIL INDIA LTD., DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

OIL INDIA LTD.,DIBRUGARH vs. ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE -2, DIBRUGARH

Bench: Shri S.S.Godara & Dr. A.L. Saini

Section 80IB for the assessment years 2003-04 and 2004-05 and benefit u/s. 80IC for the assessments years 2005-06 and 2006-07 are to be allowed.” 5. Learned senior standing counsel seeks us to treat the Revenue’s appeal ITA No.120/Gau/2008 for assessment year 2003-04 as the “lead” case raising the following substantive grounds:- ITA No.120-123/G/2008 & 87/G/10

AMIT KUMAR,DELHI vs. INCOME TAX OFFICER, WARD 1(1), GUWAHATI, INCOME TAX OFFICER

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

202,30,39,718/- was made by the Ld. AO. 3.1 Before the Ld. CIT(A) also, it was averred that the assessee was only an entry provider and hence should be assessed on the commission income which deserved to be estimated @ 0.15% to 0.25% of the total turnover. This argument has not been accepted