PAWAN COMMUNICATIONS PRIVATE LIMITED,GUWAHATI ASSAM vs. DCIT, CENTRAL CIRCLE-2, GUWAHATI

Appeal of the assessee is allowed

Bench: the learned Income Tax Appellate Tribunal [ITAT for short hereafter] expired on 17.05.2024. There is therefore a delay of about 211 (two hundred eleven) days or more till date in submitting the appeal before the said learned Tribunal.

250 on 18.03.2024. (b) However, on 21.03.2024, the said company received another Assessment Order for the same Assessment Year (A.Y. for short) 2018-19 under section 147 (pursuant to a search and seizure under section 132 of the Act) vide DIN & Order no.: ITBA/AST/S/147/2023-24/1063112122(1) wherein the assessed total income was determined at Rs. 18882165 by making addition

ASSAM GAS COMPANY LIMITED,DULIAJAN vs. DCIT/ ACIT, CIRCLE 1/DBR, DIBRUGARH

Appeal is allowed for statistical purposes

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

Section 36 and the Judgement delivered by the (a) Hon'ble 4 ITAT Pune Bench 'B' between Sharp Aluminium vs ACIT (2024) 162 taxmann.com 74 (Pune-Trib) and further judgement of (b) Hon'ble Delhi High Court in CIT, Central-II, New Delhi vs Narendra Anand (2011) 198 taxmann.com 51 Delhi endorses our said view. 5. For that other ground

GOMATI CO-OPERATIVE MILK PRODUCERS UNION LIMITED,AGARTALA vs. ACIT-NATIONAL-E-ASSEMENT CENTRE, NEW DELHI

Bench: Shri Manomohan Das, Hon’Ble & Shri Rakesh Mishra, Hon’Ble

section 250 of the Income-Tax Act, 1961 (hereinafter the ‘Act’) and pertains to the Assessment Year [AY] 2018-19. 2. The grounds of appeal of the assessee are as under: (i)For that on the facts and circumstances of the case as well as on the points of law the order passed u/s 143(3) as well

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

250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income-tax (Appeals)-Central, North-East Region, Guwahati [in short ld. “CIT(A)”] dated 30.08.2022 and ITA Nos. 37 to 39/GTY/2022 are appeals filed by the Revenue for AYs 2017-18, 2018-19 & 2019-20, respectively are directed against the order

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

250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income-tax (Appeals)-Central, North-East Region, Guwahati [in short ld. “CIT(A)”] dated 30.08.2022 and ITA Nos. 37 to 39/GTY/2022 are appeals filed by the Revenue for AYs 2017-18, 2018-19 & 2019-20, respectively are directed against the order

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

250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income-tax (Appeals)-Central, North-East Region, Guwahati [in short ld. “CIT(A)”] dated 30.08.2022 and ITA Nos. 37 to 39/GTY/2022 are appeals filed by the Revenue for AYs 2017-18, 2018-19 & 2019-20, respectively are directed against the order

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

250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income-tax (Appeals)-Central, North-East Region, Guwahati [in short ld. “CIT(A)”] dated 30.08.2022 and ITA Nos. 37 to 39/GTY/2022 are appeals filed by the Revenue for AYs 2017-18, 2018-19 & 2019-20, respectively are directed against the order

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

250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income-tax (Appeals)-Central, North-East Region, Guwahati [in short ld. “CIT(A)”] dated 30.08.2022 and ITA Nos. 37 to 39/GTY/2022 are appeals filed by the Revenue for AYs 2017-18, 2018-19 & 2019-20, respectively are directed against the order

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

GREENWOOD RESORTS PRIVATE LIMITED,GUWAHATI vs. ACIT, CENTRAL CIRCLE-1, GUWAHATI

In the result, ITA No. 114/GTY/2024 for AY 2017-18 is partly allowed for statistical purposes

Bench: Shri Manomohan Das & Shri Rakesh Mishra

250 of the Income I.T.A. Nos.: 110 to 118/GTY/2024 Assessment Years: 2014-15 to 2021-22 Greenwood Resorts Private Limited. Tax Act, 1961 (hereinafter referred to as “the Act”) for AYs 2014-15 to AY 2021-22, which have been passed against the assessment orders u/ss 153C/143(3) and 143(3) of the Act. 2. The assessee is in appeal

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.

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 and adding the same in the closing stock of the appellant nor the learned