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

Appeal is partly allowed for statistical purpose

25-26) In this case, assessee company incurred certain\nbusiness expenditure which was shown as prior-period expenditure in its balance\nsheet for AY 2003-04. However, said expenditure pertained to AY 2001-02.\nAssessee did not raise said issue before AO/ CIT(A) for the AY 2001-02. The said\nissue was raised before the Hon'ble ITAT

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

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

10,25,380/- at S.No. 3 of Table in Para 9, Page 42 of the order of FY 2015-16 (AY 2016-17). This has resulted in double consideration of same transaction. Further, the correct amount of remittance is Rs. 9,03,204/- which ought to be considered. 7. Ld. AR for assessee submitted that the additional issues/grounds

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

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

10,25,380/- at S.No. 3 of Table in Para 9, Page 42 of the order of FY 2015-16 (AY 2016-17). This has resulted in double consideration of same transaction. Further, the correct amount of remittance is Rs. 9,03,204/- which ought to be considered. 7. Ld. AR for assessee submitted that the additional issues/grounds

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

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

10,25,380/- at S.No. 3 of Table in Para 9, Page 42 of the order of FY 2015-16 (AY 2016-17). This has resulted in double consideration of same transaction. Further, the correct amount of remittance is Rs. 9,03,204/- which ought to be considered. 7. Ld. AR for assessee submitted that the additional issues/grounds

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. It is contended that the facts, circumstances and issues

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. It is contended that the facts, circumstances and issues

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. It is contended that the facts, circumstances and issues

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)

TDS was deductible by M/s. Bharti Cellular Limited when it paid interconnect charges/access/port charges to BSNL? For that purpose, we are required to examine the meaning of the words "fees for technical services" under Section 194J read with clause (b) of the Explanation to Section 194J of the Income Tax Act, 1961, [`Act', for short] which, inter alia, states that

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)

TDS was deductible by M/s. Bharti Cellular Limited when it paid interconnect charges/access/port charges to BSNL? For that purpose, we are required to examine the meaning of the words "fees for technical services" under Section 194J read with clause (b) of the Explanation to Section 194J of the Income Tax Act, 1961, [`Act', for short] which, inter alia, states that

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION) CIRCLE BHOPAL, BHOPAL vs. MAYANK WELFARE SOCIETY, INDORE

In the result, Revenue’s appeal for the AY 2013-14

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing Assessment Year: 2013-14

10(23C)(vi) was allowed by the Hon'ble Chef Commissioner of Income tax Indore vide order dated 25.06.2009. 3.2 The appellant has submitted that with a view to provide free medical aid to the poor and down trodden, it had constructed a medical college and a large hospital on Nemawar Road approx 25 kilometres away from Indore

THE DCIT, (EXEMPTION) CIRCLE, BHOPAL vs. M/S. MAYANK WELFARE SOCIETY, BHOPAL

In the result, Revenue’s appeal for the AY 2013-14

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing Assessment Year: 2013-14

10(23C)(vi) was allowed by the Hon'ble Chef Commissioner of Income tax Indore vide order dated 25.06.2009. 3.2 The appellant has submitted that with a view to provide free medical aid to the poor and down trodden, it had constructed a medical college and a large hospital on Nemawar Road approx 25 kilometres away from Indore

JCIT(OSD),-2(1),INDORE, INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

10 Kgs. to 30 Kgs. The conversion of Kgs into Bars would come to approx. 132 bars and the profit would come @ Rs.800/- per Bar to approx. Rs.1,05,600/-. The assessee has shown the gross profit ofRs.11,50,370/-. Thus, the assessee has shown more profit than estimated by the learned Assessing Officer. Complete details of purchases and sales

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

10 Kgs. to 30 Kgs. The conversion of Kgs into Bars would come to approx. 132 bars and the profit would come @ Rs.800/- per Bar to approx. Rs.1,05,600/-. The assessee has shown the gross profit ofRs.11,50,370/-. Thus, the assessee has shown more profit than estimated by the learned Assessing Officer. Complete details of purchases and sales

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

10 Kgs. to 30 Kgs. The conversion of Kgs into Bars would come to approx. 132 bars and the profit would come @ Rs.800/- per Bar to approx. Rs.1,05,600/-. The assessee has shown the gross profit ofRs.11,50,370/-. Thus, the assessee has shown more profit than estimated by the learned Assessing Officer. Complete details of purchases and sales

DCIT , CENTRAL -2 , INDORE vs. M/S GREAT GALLEON VENTURES LTD , INDORE

In the result, the appeals of the Revenue bearing ITANo

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad

25,00,000 27,00,000 5,19,998 8. Sanskriti Vintrade Pvt. SVPL - 1,49,178 4,75,000 Ltd. 50,00,000 - 5,00,002 9. SHP Financial Services SFSPL 1,81,505 1,60,397 5,72,158 Pvt. Ltd. 50,00,000 28,50,000 7,85,000 10. Amber Vyapaar Pvt. Ltd. AVPL

DCIT , CENTRAL -2 , INDORE vs. M/S GREAT GALLEON VENTURES LTD , INDORE

In the result, the appeals of the Revenue bearing ITANo

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad

25,00,000 27,00,000 5,19,998 8. Sanskriti Vintrade Pvt. SVPL - 1,49,178 4,75,000 Ltd. 50,00,000 - 5,00,002 9. SHP Financial Services SFSPL 1,81,505 1,60,397 5,72,158 Pvt. Ltd. 50,00,000 28,50,000 7,85,000 10. Amber Vyapaar Pvt. Ltd. AVPL

THE DCIT,1(1), INDORE vs. M/S. RITSPIN SYNTHETICS LTD., PITHAMPUR

In the result, the appeal filed by the Department is allowed for statistical purposes, in terms indicated above, and the cross-objections filed by the assessee are dismissed as not pressed

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

10,00,000/- made under section 68 was not sustainable and deleted the same. Consequent to the deletion of the principal addition, the learned CIT(A) further held that the disallowance of interest of ₹25,27,261/- under section 69C of the Act could not survive, ITA No. 213/Ind/2023 & C.O. 4/Ind/2024 ACIT vs. M/s. Ritspin Synthetic Pvt. Ltd. & M/s. Ritspin

M/S. BHARTI AIRTEL LIMITED,INDORE vs. THE ITO TDS-II, INDORE

In the result, appeals of assessee are allowed for statistical purposes

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

TDS) under section 154/201(1)/201(1A), levying interest under section 220(2). 2.The Ld. CIT(A) has erred both on facts and in law in confirming that interest under section 220(2) is levied on a calendar month basis instead of number of days (30 or 31, as the case may be): 2.1.Ld. CIT(A) erred in not appreciating