MADHYA PRADESH TODAY MEDIA LTD.,BHOPAL vs. ITO-TDS, INDORE

In the result, the ground of appeal is partly allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

TDS quarterly returns and Ld. CIT(A) confirming such levy of fee u/s 234E at Rs.1,02,750/- (24Q- II), Rs.96,722/(24Q-III) -, Rs.63,842/- (24 Q-IV), Rs. 1,21,903/- (26 Q-II), Rs.97,355/-(26 Q-III) and Rs.63,842/- (26 Q-IV) respectively ITANos. 574 to 579/Ind/2019 Madhya Pradesh Today Media Pvt. Ltd for Financial

MADHYA PRADESH TODAY MEDIA LTD.,BHOPAL vs. ITO-TDS, INDORE

In the result, the ground of appeal is partly allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

TDS quarterly returns and Ld. CIT(A) confirming such levy of fee u/s 234E at Rs.1,02,750/- (24Q- II), Rs.96,722/(24Q-III) -, Rs.63,842/- (24 Q-IV), Rs. 1,21,903/- (26 Q-II), Rs.97,355/-(26 Q-III) and Rs.63,842/- (26 Q-IV) respectively ITANos. 574 to 579/Ind/2019 Madhya Pradesh Today Media Pvt. Ltd for Financial

MADHYA PRADESH TODAY MEDIA LTD.,BHOPAL vs. ITO-TDS, INDORE

In the result, the ground of appeal is partly allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

TDS quarterly returns and Ld. CIT(A) confirming such levy of fee u/s 234E at Rs.1,02,750/- (24Q- II), Rs.96,722/(24Q-III) -, Rs.63,842/- (24 Q-IV), Rs. 1,21,903/- (26 Q-II), Rs.97,355/-(26 Q-III) and Rs.63,842/- (26 Q-IV) respectively ITANos. 574 to 579/Ind/2019 Madhya Pradesh Today Media Pvt. Ltd for Financial

MADHYA PRADESH TODAY MEDIA LTD.,BHOPAL vs. ITO-TDS, INDORE

In the result, the ground of appeal is partly allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

TDS quarterly returns and Ld. CIT(A) confirming such levy of fee u/s 234E at Rs.1,02,750/- (24Q- II), Rs.96,722/(24Q-III) -, Rs.63,842/- (24 Q-IV), Rs. 1,21,903/- (26 Q-II), Rs.97,355/-(26 Q-III) and Rs.63,842/- (26 Q-IV) respectively ITANos. 574 to 579/Ind/2019 Madhya Pradesh Today Media Pvt. Ltd for Financial

M/S TESLA TRANSFORMERS ,BHOPAL vs. ITO(INTERNATIONAL TAXATION),, BHOPAL

In the result, Ground Numbers 1 to 4 of assessee’s appeal are dismissed

TDS default u/s 195 amounting to Rs.27,66,720/- u/s 201(1) of the Act. 3. That the ld. CIT(A) erred in holding that in the transaction of import of raw- material valuing Rs.4,02,92,017/- from foreign companies , income accrued under the provisions of section

SNAP COMPUTER SYSTEMS PVT. LTD.,INDORE vs. ITO (INTERNATIONAL TAXATION & TRANSFER PRICING), BHOPAL

Bench: Shri Kul Bharat & Shri Manish Borad

section 195/201 of the Income Tax Act. 02. That on the facts and circumstances of the case the Ld. CIT(A) has erred in confirming the action of the Ld. ITO by holding that services provided by System Integration Inc. USA are covered as fees under the India-USA double taxations avoidance agreement (DTAA) and hence taxable under Article

SNAP COMPUTER SYSTEM (P) LTD.,INDORE vs. ITO (INTER TAXATION & TRANSFER PRICING), BHOPAL

Bench: Shri Kul Bharat & Shri Manish Borad

section 195/201 of the Income Tax Act. 02. That on the facts and circumstances of the case the Ld. CIT(A) has erred in confirming the action of the Ld. ITO by holding that services provided by System Integration Inc. USA are covered as fees under the India-USA double taxations avoidance agreement (DTAA) and hence taxable under Article

ITO 2(5), INDORE vs. M/S I PARADISE INFOMEDIA P LTD., INDORE

In the result, Revenue’s appeal is dismissed

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

02,145/- as ‘advertisement expenses’ and Rs.70,32,022/- as ‘ business promotion expenses’ under other expenses in the P&L account. On 02.03.2016, the assessee was asked as to why TDS has not been made at the time of payment in terms of Provision of Section

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

TDS @ remittance thereon remitted of amount per 41.2% u/s in Rs. remitted section incld. cess 201(1A) 195A of the Act Buhler 283438 28344 47240 19463 August 15 3892 Switzerland 5. Aggrieved assessee preferred appeals before Ld. CIT(A) but failed to succeed and now the assessee is in appeal before the Tribunal on the common issues raised in both

M/S SANGHVI FOODS P LTD, ,INDORE vs. ITO (IT & TP) , BHOPAL

In the result common issue raised in

Bench: Shri Kul Bharat & Shri Manish Borad

TDS @ remittance thereon remitted of amount per 41.2% u/s in Rs. remitted section incld. cess 201(1A) 195A of the Act Buhler 283438 28344 47240 19463 August 15 3892 Switzerland 5. Aggrieved assessee preferred appeals before Ld. CIT(A) but failed to succeed and now the assessee is in appeal before the Tribunal on the common issues raised in both

SHIVGANGA DRILLERS P LTD,INDORE vs. CPC , BENGALURU

In the result, the appeal of assessee is allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

02,513/- u/s 36 of the Income Tax without giving nature of the above disallowance and more so without considering the facts of the case and contents of return filed by the appellant. b) That on the facts and in the circumstances of the case and in law the Ld. A.O. (CPC) erred in not allowing credit for TDS

M/S D & H SECHERON ELECTRODES PVT. LTD,INIDORE vs. ITO (IT & TP), BHOPAL

In the result appeal of the assessee stands allowed

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2016-17 M/S. D&H Secheron Electrodes Ito (It & Tp), Pvt. Ltd, Vs. Bhopal 44-46, Industries Estate, Kila Maidan, Indore (Appellant) (Respondent ) Pan No.Bpld00066D

TDS on t his payment. 02]. The assessee reserve its right to add, alter, modify or amend the grounds of appeal as and when required. 3. Brief facts relating to this issue are that the assessee is engaged in the business of manufacturing of welding electrodes. The assessee is responsible for deducting tax at source under Chapter XVII

HERSHEY INDIA P.LTD,MUMBAI vs. ITO ( INTERNATIONAL TAXATION & TRANSFER PRICING) , BHOPAL, BHOPAL

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

section 133 (6) of the Act. Accordingly, the TDS Officer held that assessee was liable to deduct tax at source (TDS) on such payments for purchase of machinery and therefore, the assessee has defaulted in not deducting TDS at the time of making payment for purchase of machinery to Reda, Italy. 5. In appeal, Ld. CIT(Appeals) dismissed the assessee

HERSHEY INDIA P.LTD,MUMBAI vs. ITO ( INTERNATIONAL TAXATION & TRANSFER PRICING) , BHOPAL, BHOPAL

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

section 133 (6) of the Act. Accordingly, the TDS Officer held that assessee was liable to deduct tax at source (TDS) on such payments for purchase of machinery and therefore, the assessee has defaulted in not deducting TDS at the time of making payment for purchase of machinery to Reda, Italy. 5. In appeal, Ld. CIT(Appeals) dismissed the assessee

SOM DISTILLERIES AND BREWERIES LTD.,BHOPAL vs. ITO-1(1), BHOPAL

Appeal is partly allowed for statistical

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniay: 2013-14 Som Distilleries & Income-Tax Officer, बनाम/ Breweries Limited, 1(1), Vs. Som House, Bhopal. 23, Zone Ii, M.P. Nagar, Bhopal (Pan: Aabcs3374B) (Assessee/Appellant) (Revenue/Respondent) Ay:2014-15 Acit (Central)-1, Som Distilleries & बनाम/ Bhopal Breweries Limited, Vs. Som House, 23, Zone Ii, M.P. Nagar, Bhopal (Pan: Aabcs3374B) (Revenue/Appellant) (Assessee/Respondent)

section 14A and made disallowance of Rs. 7,02,964/- consisting of two elements in terms of Rule 8D, viz. (i) Interest disallowance under Rule 8D(2)(ii) computed at Rs. 75,807/- and (ii) standard disallowance @ 0.50% of the average investments of Rs. 12,54,41,410/- made in the shares yielding the exempted dividend, computed

ACIT (CENTRAL)-1, BHOPAL, BHOPAL vs. SOM DISTILLERIES AND BREWERIES LTD., BHOPAL

Appeal is partly allowed for statistical

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniay: 2013-14 Som Distilleries & Income-Tax Officer, बनाम/ Breweries Limited, 1(1), Vs. Som House, Bhopal. 23, Zone Ii, M.P. Nagar, Bhopal (Pan: Aabcs3374B) (Assessee/Appellant) (Revenue/Respondent) Ay:2014-15 Acit (Central)-1, Som Distilleries & बनाम/ Bhopal Breweries Limited, Vs. Som House, 23, Zone Ii, M.P. Nagar, Bhopal (Pan: Aabcs3374B) (Revenue/Appellant) (Assessee/Respondent)

section 14A and made disallowance of Rs. 7,02,964/- consisting of two elements in terms of Rule 8D, viz. (i) Interest disallowance under Rule 8D(2)(ii) computed at Rs. 75,807/- and (ii) standard disallowance @ 0.50% of the average investments of Rs. 12,54,41,410/- made in the shares yielding the exempted dividend, computed

SHRI SURENDRA SINGH BHATIA,INDORE vs. THE JCIT-3, INDORE

In the result, assessee’s appeal is allowed

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

02,129/- stood deleted by the Ld. CIT(A) on 30.11.2011. On 06.03.2013, penalty amounting to Rs.2,48,97,638/- was imposed under Section 271AAA of the Act @ 10% of the concealed income, which was, in turn, confirmed by the Ld. CIT(A). Hence, the instant appeal before us. 4. On 29.12.2009, the following show cause notice under Section 271D

SHRI SHALIGRAM BAROD, ,INDORE vs. PR. CIT-1, INDORE

Bench: Hon'Ble Manish Borad & Hon'Ble’ Madhumita Royassessment Year:2014-15 Shri Shaligram Barod, Pr. Cit-I, Ah/29, Hig, Sukhliya Indore बनाम/ Indore Vs. (Appellant) (Respondent ) P.A. No. Ahfpp4068H Appellant By Shri S.N. Agrawal, Ca Revenue By Shri S.B. Prasad, Cit-Dr

02-2016 CIT vs Shimbhu Mehra ITA No 373 of 2010 dt 12-10- 2015 [ 236 Taxman 561(All) ITO vs Modipon Ltd 168 TTJ 480 ( Del) Hari Mohan Das Tandon 169 ITD 639 ( All) (HUF) vs PCIT Kundaben Ambhai Shah ITA No 3354/ Ahd/ 2014 dt 30- v. ITO 11-2017 Dharamhi Bhai Sonani