M/S. ASSAM CARBON PRODUCTS LIMITED,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3, GUWAHATI

In the result, the revenue’s appeal for the AY 2014-15 is dismissed and that of assessee’s appeal for the AY 2012-13 is allowed

6 dispensation of Section 43A, the effect of increase or decrease of liability could only arise at the point of payment, as the point of accrual shifts to the point of payment. 27. Learned counsel next contended that on a proper and true interpretation of the amendment to Section 43A, introduced by Finance Act, 2002, Section 43A is clarificatory. According

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-TINSUKIA, TINSUKIA vs. M/S. BROOKE BOND INDIA LIMITED, MUMBAI

In the result, appeal of the revenue and the cross-objection of the assessee are dismissed

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Ble]

43,000 1988-89 Rs. 83,42,000 1989-90 Rs. 74,00,000 1990-91 Rs. 1,83,00,000 1991-92 Rs. 2,00,00,000 1992-93 Rs. 1,45,00,000 The Assessing Officer has held especially that as there is no provision in sections 32AB and 33AB analogous to section 32A (6

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, GUWAHATI vs. M/S. PAWAN CEMENT COMPANY PRIVATE LIMITED, GUWAHATI

In the result, both the appeals filed by the Revenue for AY

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

6 of 24 I.T.A. Nos.: 72 & 73/GTY/2020 Assessment Years: 2011-12 & 2013-14 Pawan Cement Company Pvt. Ltd. has been held that even if the statement has not been retracted then also the addition cannot be made merely on the basis of the statement without the support of any incriminating material found during the course of search. The case

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, GUWAHATI vs. M/S. PAWAN CEMENT COMPANY PRIVATE LIMITED, GUWAHATI

In the result, both the appeals filed by the Revenue for AY

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

6 of 24 I.T.A. Nos.: 72 & 73/GTY/2020 Assessment Years: 2011-12 & 2013-14 Pawan Cement Company Pvt. Ltd. has been held that even if the statement has not been retracted then also the addition cannot be made merely on the basis of the statement without the support of any incriminating material found during the course of search. The case

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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the Assessment Year

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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the Assessment Year

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

In the result, appeals of the assessee in I

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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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

Disallowance of claim of deduction of expenditure for 'Corporate Social Responsibility' made following Guidelines issued by the Government. Ground and Assessment Year Amount Ground No.(6) for the Assessment Year 2007-08; Rs. 309,08,755/- Ground No.(6) for the Assessment Year 2008-09 Rs. 350,25,274/- Ground No.(7) for the 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.

43,73,603/-. Accordingly, Ground No. 1 (a) & 1(b), raised by the assessee are allowed. 5 Jyoti Prakash Das A.Y. 2017-18 9. Ground No. 2 raised by the assessee relates to the confirmation of disallowance of Rs.18,16,738/- made by the AO u/s 40A(3) of the Act. 10. The ld. A/R submitted that assessee has undertaken

VISHASH AGARWAL,TINSUKIA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, DIBRUGARH

In the result, the appeal of the assessee stand dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.39/Gty/2021 Assessment Year: 2018-19 Vishesh Agarwal…………………..……....….........…..........….…… Appellant C/O Assam Pushpak Travel Agency, Makum Road, Tinsukia, Assam – 786170. [Pan: Aghpa7072R] Vs. Acit, Circle-1, Dibrugarh……………..….…..…...…..…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Soumendu Sekhar Das, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 20, 2023 Date Of Pronouncing The Order : September 20, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 17.03.2020 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Sole Issue Involved In These Appeals Is Relating To The Disallowance Made By The Assessing Officer/Central Processing Centre (Cpc) U/S 36(1)(Va) R.W.S. 2(24)(X) Of The Act On Account Of Delayed Deposit Of Employees’ Contribution To Pf/Esi I.E. After The Due Date As Provided Under The Respective Welfare Enactments.

6. Such being the position, the deletion of the amount paid by the Employees’ Contribution beyond due date was deductible by invoking the aforesaid amended provisions of Section 43(B) of the Act. 7. We, therefore, find that no substantial question of law is involved in this appeal and consequently, we dismiss this appeal.” A perusal of the above observations

HEMENDRA NATH DEKA,GUWAHATI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CPC, BENGALURU

In the result, both the captioned appeals of the assessee stand dismissed

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. Nos.5&6/Gau/2022 Assessment Years: 2018-19 & 2019-20 Hemendra Nath Deka…………....…………....….........…..........….…… Appellant House No.6, Dolphin Security & Advertising, Kamakhya Temple Road, Kamakhya Gate, Guwahati-781009, Kamrup, Assam. [Pan: Ajupd3564F] Vs. Acit, Cpc, Bengaluru (Ito, Ward-1(2), Guwahati)…...…..…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri N. T. Sherpa, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 05, 2023 Date Of Pronouncing The Order : June 05, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 09.12.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Sole & Common Issue Involved In Both The Appeals Is Relating To The Disallowance Made By The Assessing Officer/Central Processing Centre (Cpc) U/S 36(1)(Va) R.W.S. 2(24)(X) Of The Act On Account Of Delayed Deposit Of Employees’ Contribution To Pf/Esi I.E. After The Due Date As Provided Under The Respective Welfare Enactments.

6. Such being the position, the deletion of the amount paid by the Employees’ Contribution beyond due date was deductible by invoking the aforesaid amended provisions of Section 43(B) of the Act. 7. We, therefore, find that no substantial question of law is involved in this appeal and consequently, we dismiss this appeal.” A perusal of the above observations

HEMENDRA NATH DEKA,GUWAHATI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CPC, BENGALURU

In the result, both the captioned appeals of the assessee stand dismissed

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. Nos.5&6/Gau/2022 Assessment Years: 2018-19 & 2019-20 Hemendra Nath Deka…………....…………....….........…..........….…… Appellant House No.6, Dolphin Security & Advertising, Kamakhya Temple Road, Kamakhya Gate, Guwahati-781009, Kamrup, Assam. [Pan: Ajupd3564F] Vs. Acit, Cpc, Bengaluru (Ito, Ward-1(2), Guwahati)…...…..…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri N. T. Sherpa, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 05, 2023 Date Of Pronouncing The Order : June 05, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 09.12.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Sole & Common Issue Involved In Both The Appeals Is Relating To The Disallowance Made By The Assessing Officer/Central Processing Centre (Cpc) U/S 36(1)(Va) R.W.S. 2(24)(X) Of The Act On Account Of Delayed Deposit Of Employees’ Contribution To Pf/Esi I.E. After The Due Date As Provided Under The Respective Welfare Enactments.

6. Such being the position, the deletion of the amount paid by the Employees’ Contribution beyond due date was deductible by invoking the aforesaid amended provisions of Section 43(B) of the Act. 7. We, therefore, find that no substantial question of law is involved in this appeal and consequently, we dismiss this appeal.” A perusal of the above observations