NARENDRA KUMAR MISHRA,BHOPAL vs. ITO-3(1), BHOPAL, BHOPAL

Appeal is partly allowed for statistical purpose

14 (XL 35) dated 11-04-1955,\ninsists on the respondent department not to take advantage of the ignorance of\nthe assessee: -\n\"Officers of the department must not take advantage of the ignorance of an\nassessee as to his rights. It is one of their duties to assist a tax payer in every\nreasonable way, particularly in the matter

D.K CONSTRUCTION,BHOPAL vs. THE ITO 2 (3), BHOPAL

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

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanid. K Construction Ito 2(3) E 2/21, Pandit Deeendayal Bhopal Complex, Arera Colony, Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaafd7121P Assessee By Shri S.S. Deshpande, Ar Shri Ram Kumar Yadav, Cit- Dr Revenue By Date Of Hearing 04.09.2024 Date Of Pronouncement 09 .09.2024

TDS.” 2. At the time of hearing Ld. AR of the assesse has stated at bar that due to smallness of disallowance the assessee does not press ground no.2 of the grounds of appeal and the same may be dismissed as not pressed. Ld. DR has raised no objection if ground no.2 of the assesse’s appeal is dismissed

SUPREME TRANSPORT COMPANY,INDORE vs. ITO TDS-II, INDORE

In the result, all the appeals filed by the assessees are allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

14. The Hon'ble High Court thus held that where the impugned notices given by Revenue Department under section 200A of the Act were for the period prior to 1-6-2015, then same were illegal and invalid. Vide para 27, it was further held that the impugned notices under section 200A of the Act were for computation and intimation

SUPREME TRANSPORT COMPANY,INDORE vs. ITO TDS-II, INDORE

In the result, all the appeals filed by the assessees are allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

14. The Hon'ble High Court thus held that where the impugned notices given by Revenue Department under section 200A of the Act were for the period prior to 1-6-2015, then same were illegal and invalid. Vide para 27, it was further held that the impugned notices under section 200A of the Act were for computation and intimation

GUNVEER SINGH CHHABRA ,INDORE vs. THE PR CIT -1, INDORE

In the result, assessee’s appeal is allowed

Bench: Ms. Madhumita Roy, Judicial Memebr & Shri Bhagirath Mal Biyani

TDS has been made by the said party on payment of the said interest. The Ld.PCIT was of the view that there was an under assessment of income of Rs.1,67,00,000/- as worked out @12% rate of interest. The issues were directed to be re-examined by the Ld.AO. 4. We have heard the rival submissions made

THEACIT CENTRAL-2, INDORE, INDORE vs. M/S KETI CONSTRUCTION LTD., INDORE

In the result, appeal of revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit(Central)-2 M/S Keti Construction Ltd Indore Vastalya Chamebers, Sapna Sangeeta, 31/6, Sneh Nagar Vs. Main Road, Indore

TDS u/s 40a(ia) of the Page 3 of 14 ITA No.329 /Ind/2022 Keti Construction ltd. Page 4 of 14 Act. Thus, about 50% of the total expenses debited in the profit and loss account were already disallowed by the assessee while computing total income in view of the provision of section 40a(ia) whereas the AO has made

BMG CALCUTTAWALA JEWELLERS PVT. LTD.,INDORE vs. AO CPC (TDS), ITO TDS(1) INDORE, INDORE

Appeals are allowed\"

10-9-2014]\nMeeraj Estate\n& Developers v. Dy.\nCIT [2014] 44 taxmann.com 431/148 ITD\n166 (ITAT, Agra)\n(iv)\nK.K.\nKhullar v. Dy.\n301(Delhi)\nCIT [2009] 116\nITD\n(v)\nDwarkadas Kesardeo Morarka v. CIT [1962]\n44 ITR 529 (SC)\n6. The Id. DR drew the attention of the Bench to the\nMemorandum to the Finance Bill

DISHA EDUCATION SOCIETY,RAIPUR vs. COMMISSIONER OF INCOME TAX, EXEMPTION, BHOPAL

In the result, both appeals of assessee are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

10 of 14 ITA No.164 & 165/Ind/2023 Disha Education Society Page 11 of 14 (e) Xxxxx (f) The trust or institution has not complied with the requirement of any other law, as referred to in item (B) of sub-clause(i) of clause (b) of sub-section (1) and the order direction or decree by whatever name called holding that such

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

10,18,92,350/-. Respectfully following above judicial precedents, we hold that these charges are not fees for rendering any technical services as envisaged in Section 194J of the Act. Therefore, we reverse the order of the ld CIT (A) and assessee's appeal is allowed on this ground also.” 14. Reading of the above order clearly show that fact

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

10,18,92,350/-. Respectfully following above judicial precedents, we hold that these charges are not fees for rendering any technical services as envisaged in Section 194J of the Act. Therefore, we reverse the order of the ld CIT (A) and assessee's appeal is allowed on this ground also.” 14. Reading of the above order clearly show that fact

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

10,18,92,350/-. Respectfully following above judicial precedents, we hold that these charges are not fees for rendering any technical services as envisaged in Section 194J of the Act. Therefore, we reverse the order of the ld CIT (A) and assessee's appeal is allowed on this ground also.” 14. Reading of the above order clearly show that fact

PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS. The assessee carried matter in first appeal but could not succeed. 10. Before us, Ld.AR for assesseeneither claimed that the impugned payments do not fall in the definition of “FTS” prescribed in Explanation 2 to section 9(1)(vii) nor even claimed that the payees did not render service in India or the payees do not have any agent

PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS. The assessee carried matter in first appeal but could not succeed. 10. Before us, Ld.AR for assesseeneither claimed that the impugned payments do not fall in the definition of “FTS” prescribed in Explanation 2 to section 9(1)(vii) nor even claimed that the payees did not render service in India or the payees do not have any agent

PERMALI WALLACE PVT. LTD,BHOPAL vs. ITO (IT & TP), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

TDS. The assessee carried matter in first appeal but could not succeed. 10. Before us, Ld.AR for assesseeneither claimed that the impugned payments do not fall in the definition of “FTS” prescribed in Explanation 2 to section 9(1)(vii) nor even claimed that the payees did not render service in India or the payees do not have any agent

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

10,18,92,350/-. Respectfully following above judicial precedents, we hold that these charges are not fees for rendering any technical services as envisaged in Section 194J of the Act. Therefore, we reverse the order of the ld CIT (A) and assessee's appeal is allowed on this ground also.” 14. Reading of the above order clearly show that fact

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

10,18,92,350/-. Respectfully following above judicial precedents, we hold that these charges are not fees for rendering any technical services as envisaged in Section 194J of the Act. Therefore, we reverse the order of the ld CIT (A) and assessee's appeal is allowed on this ground also.” 14. Reading of the above order clearly show that fact

SHRI PREMNARAYAN,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

10:30 AM. You are requested to attend in person or through an authorized representative to submit your representation, if any alongwith supporting documents/information in support of the Issues Involved (as mentioned below). If you wish that the Revision proceeding be concluded on the basis of your written submissions/representations filed in this office, on or before the said due date

SMT. SHARDA,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

10:30 AM. You are requested to attend in person or through an authorized representative to submit your representation, if any alongwith supporting documents/information in support of the Issues Involved (as mentioned below). If you wish that the Revision proceeding be concluded on the basis of your written submissions/representations filed in this office, on or before the said due date