COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

exemption u/s 10A/10B, (iii) capitalization of civil & tiling work in leasehold premise, (iv) depreciation on software, and (v) disallowance u/s 14A. With

M/S. MADHURI REFINERS (P) LTD.,INDORE vs. DCIT-3(1), INDORE

In the result, this appeal of assessee is allowed

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 M/S. Madhuri Refiners Dcit, 3(1) Private Ltd., Indore Indore Vs. (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcm 1884 C Assessee By Shri Pankaj Shah, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.09.2022 Date Of Pronouncement 21.09.2022 O R D E R Per B.M. Biyani, A.M.:

depreciation” itself is as high as Rs. 20,25,596/-. Ld. AR also emphasised that the assessee has been consistently regarded as “manufacture” by various Government Department and Agencies. The process undertaken by the assessee have been treated as manufacture under Excise Act and allied tax laws, although the excise-duty is exempt

NIRVINDHYA SHIKSHA AVAM SANSKRITI PRACHAR SAMITI,RAJGARH vs. ITO, RAJGARH

Appeal is allowed for statistical purpose

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2017-18 Nirvindhya Shiksha Avam Income-Tax Officer, Sanskriti Prachar Samiti, Rajgarh Biaora, C/O Adv. Hitesh Chimnani, बनाम/ Ug-37, Trade Centre, Vs. 18,South Tukoganj, Indore. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaaan8371J Assessee By Shri Hitesh Chimnani, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 05.09.2024 Date Of Pronouncement 10.09.2024

exemption u/s 11/12 of the Act. The return was taken up by AO for scrutiny-assessment through notices u/s 143(2)/142(1). During scrutiny-proceedings, the AO observed that the assessee has claimed ‘depreciation

SCIENCE FORUM FOR RURAL DEVELOPMENT AND RESEARCH,GRAM MINDIA, SANVER ROAD vs. CIT(A), UJJAIN

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2017-18

exemption cannot be given unless it is claimed by the assessee. For the year under consideration the assessee has not fled the Return of Income. To arrive excess of income over expenditure the assessee has claimed depreciation

RAISEN MARKETING P LTD,BHOPAL vs. THE ADIT CPC , BGHOPAL

In the result, the present appeal is allowed in so far as it relates\nto adjudication of Ground No

exempt income and disallowed u/s 14A (16\nof Part A-OI)\n8b\n0\n9.\nTotal (7a + 7b +7c+ 7d+ 7e + 8a+ 8b)\n9\n0\n10. Adjusted profit or loss (6+9)\n10\n51829125\n11. Depreciation

DILIP BUILDCON LTD ,BHOPAL vs. DCIT CENTRAL-1, BHOPAL

In the result, appeal of Assessee is allowed

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2018-19 M/S. Dilip Buildcon Ltd. Acit Central-1 Bhopal Bhopal बनाम/ Vs. (Appellant / Assessee) (Respondent /Revenue) Pan: Aaccd 6124 B Assessee By Shri Hitesh Chimnani & Shri Yash Kukreja, Ld. Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 18.10.2022 Date Of Pronouncement 20.10.2022

depreciation under section 32(1)(iia) for the machinery used for manufacturing ready mix concrete ?...... 7. The learned standing counsel for the Government of India (Taxes) would however point out that the assessee is principally engaged in the business of construction work and even if the assessee is involved in an additional manufacturing activity, it cannot qualify for exemption

ACIT(CENTRAL)-1, BHOPAL, BHOPAL vs. DILIP BUILDCON LIMITED, BHOPAL

Appeals are dismissed

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

exemption' is another"? 4. Whether on the facts and on the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 74,88,99,590/- made by the AO on account of disallowance of additional depreciation

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL, BHOPAL vs. DILIP BUILDCON LIMITED, BHOPAL

Appeals are dismissed

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

exemption' is another"? 4. Whether on the facts and on the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 74,88,99,590/- made by the AO on account of disallowance of additional depreciation

BAL BHAVAN SCHOOL,BHOPAL vs. DCIT EXEMPTION, BHOPAL

Appeal is allowed as mentioned above

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2014-15 Bal Bhavan School, Dcit (Exemption), 1, Shyamla Hills, Bhopal बनाम/ Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaaab3678G Assessee By Ms. Nisha Lahoti, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 15.05.2024 Date Of Pronouncement 10.06.2024

exempt u/s 11 and does not attract a single penny of tax. On the other hand, the payees have paid tax in the highest bracket of 30%+Cess on income arising from impugned rental payments. When it is so, why would the assessee and the payees (who are closely-connected persons of assessee) make a tax-inefficient arrangement unless there

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

exempt income. 4. That on the facts and circumstances of the case and in law, the CIT(A) in sustaining the disallowance of Rs. 6,54,95,133/- did not appreciate that: (i) administrative expenses debited to the profit and loss account had no bearing to the earning of dividend and non current investment. (ii) non-current investment of Rs.1417.46

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

exempt income. 4. That on the facts and circumstances of the case and in law, the CIT(A) in sustaining the disallowance of Rs. 6,54,95,133/- did not appreciate that: (i) administrative expenses debited to the profit and loss account had no bearing to the earning of dividend and non current investment. (ii) non-current investment of Rs.1417.46

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

exempt income. 4. That on the facts and circumstances of the case and in law, the CIT(A) in sustaining the disallowance of Rs. 6,54,95,133/- did not appreciate that: (i) administrative expenses debited to the profit and loss account had no bearing to the earning of dividend and non current investment. (ii) non-current investment of Rs.1417.46

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. ACIT CENTRAL-II, BHOPAL

In the result, appeal of the assessee in ITANo

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

exemption can be a subject matter but continuing of registration u/s 12AA of the Act cannot be challenged. Accordingly ground no.7 is dismissed as infructuous. 18. As a result, this appeal ITANo.90/Ind/2019 is partly allowed. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 Now we take up ITANo.548/Ind/2019 19. At the cost of repetition the brief facts are that subsequent

M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

exemption can be a subject matter but continuing of registration u/s 12AA of the Act cannot be challenged. Accordingly ground no.7 is dismissed as infructuous. 18. As a result, this appeal ITANo.90/Ind/2019 is partly allowed. Shri Jairam Education Society ITA No.90 & 548/Ind/2019 Now we take up ITANo.548/Ind/2019 19. At the cost of repetition the brief facts are that subsequent

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNE vs. THE ACIT NFAC, DELHI

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

depreciation of INR 58,48,669) in respect of the subsidies received from Government of Madhya Pradesh under the Industrial Promotion Policy, 2004 by treating the same as revenue receipt. Prayer: The Appellant prays that the addition made by Ld. AO and Hon'ble DRP be deleted and the Ld. AO be directed to treat the amount

NATIONAL LAW INSTITUTE UNIVERSITY ,BHOPAL vs. DCIT(EXEMPTION), BHOPAL

Appeal is allowed in terms mentioned above

Exemption) (2025) 170 Taxman.com\n743 (Delhi – Trib.):\n\"17. Considered the rival submissions and material placed on record. We\nobserved from the record that the assessee a GOI undertaking established\nwith the sole purpose of making the artificial limbs and its accessories to\nneedy persons in particular to the disable persons at reasonable cost. In this\nprocess, it has established

MALWA OXYGEN AND INDUSTRIAL GASES PRIVATE LIMITED ,SECTOR C, INDUSTRIAL AREA vs. AO-RATLAM/INCOME TAX OFFICER, NFAC, RATLAM/DELHI

Appeal is partly allowed for statistical purposes

depreciation of Rs.\n2,65,234/- on capital expenditure of Rs.27,68,375/-. The assessee agreed\nfor 'net disallowance' of Rs.51,27,306/- [Rs.78,72,495 (-) Rs.24,79,955 (-) Rs.\n2,65,234]; voluntarily paid differential tax and submitted challan to AO.\nHowever, the AO disallowed the deduction of Rs.78,72,495/- in entirety\nwithout giving any benefit of alternative

GOVIND HARINARAYAN AGRAWAL HUF,INDORE vs. I T O 2(1), INDORE

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2014-15

exempted LTGC based on information/statement Shivnarayan Sharma & Ors ITA Nos. 889/Ind/2018,474,206,60,987/Ind/2019 gathered by investigation wing of the department, without any opportunity to cross examine such persons and without providing such documents for assessee’s comments, which is quite unjust, illegal and against the facts of the case. 8. That the learned CIT(A) has erred