M/S. SANWARIA AGROILS LIMITED,BHOPAL vs. THE ACIT 1(1), BHOPAL

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Mohan Garg & Shri O.P.Meena

E R PER O.P. MEENA, ACCOUNTANT MEMBER. This appeal filed by the assessee is directed against the order of Learned Commissioner of Income-tax (Appeals)-I, Bhopal [in short “the CIT(A)”] dated 19-09-2013 pertaining to Assessment Year 2007-08, which in turn has arisen from the order dated passed by the ACIT 1(1) Bhopal (in short

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

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

E R Per Bench: Feeling aggrieved by undermentioned appeal-orders passed by Commissioner of Income-tax (Appeal) [“CIT(A)”], the assessee and revenue both have filed the captioned cross-appeals for different assessment-years [“AY”], which in turn arise out of respective assessment-orders passed by Page 1 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019

ASIAN BUSINESS CONECTION PVT. LTD.,BHOPAL vs. DCIT - 1(1) , BHOPAL

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2015-16 M/S. Asian Business Dcit-1(1), Connections Private Ltd, Vs. Bhopal Fm-18, Man Sarovar Complex, 7No. Stop, Shivaji Nagar, Bhopal (Appellant) (Respondent ) Pan No.Aaica1206D

13. To demonstrate that the transaction is a business transaction ABCPL filed the following evidences before the lower authorities:- i. Memorandum of Association of ABC. ii. Memorandum of Association of AOPL. iii. AOPL’s Board Resolution for the board meeting held on 25th September 2012. iv. AOPL’s Board Minutes for the board meeting held on 25th September

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

Appeals are allowed

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

e-mail dated 11th April 2022 on the above-mentioned subject. In this regard, I am directed to convey that SLP in the case of CIT (TDS), Bangalore v. Vodafone South Ltd. (2016) 72 Taxmann.com 347 (Kar) has not been approved by Board for the following reason: "As it has been repeatedly established in various cases, involving the issue

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

Appeals are allowed

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

e-mail dated 11th April 2022 on the above-mentioned subject. In this regard, I am directed to convey that SLP in the case of CIT (TDS), Bangalore v. Vodafone South Ltd. (2016) 72 Taxmann.com 347 (Kar) has not been approved by Board for the following reason: "As it has been repeatedly established in various cases, involving the issue

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

Appeals are allowed

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

e-mail dated 11th April 2022 on the above-mentioned subject. In this regard, I am directed to convey that SLP in the case of CIT (TDS), Bangalore v. Vodafone South Ltd. (2016) 72 Taxmann.com 347 (Kar) has not been approved by Board for the following reason: "As it has been repeatedly established in various cases, involving the issue

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)

e-mail dated 11th April 2022 on the above-mentioned subject. In this regard, I am directed to convey that SLP in the case of CIT (TDS), Bangalore v. Vodafone South Ltd. (2016) 72 Taxmann.com 347 (Kar) has not been approved by Board for the following reason: "As it has been repeatedly established in various cases, involving the issue

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)

e-mail dated 11th April 2022 on the above-mentioned subject. In this regard, I am directed to convey that SLP in the case of CIT (TDS), Bangalore v. Vodafone South Ltd. (2016) 72 Taxmann.com 347 (Kar) has not been approved by Board for the following reason: "As it has been repeatedly established in various cases, involving the issue

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

E R Per B.M. Biyani, A.M.: Feeling aggrieved by appeal-order dated 26.06.2023 passed by learned Commissioner of Income-Tax (Appeals), NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated 23.12.2016 passed by learned DCIT (Exemption), Bhopal [“AO”] u/s 143(3) of the Income-tax Act, 1961 [“the Act”] for Assessment-Year

THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL vs. DB POWER LTD, BHOPAL

Appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

e) That, without prejudice to the above, the learned CIT(A) grossly erred, both on facts and in law, in upholding the AO's allegation of bogus payments to vendors, merely on the basis of certain excel sheets recovered from some personal email correspondence by one of the ex-employees of the appellant company, without considering and appreciating the material

DB POWER LTD,BHOPAL vs. THE ACIT,CENTRAL CIRCLE-1, BHOPAL, BHOPAL

Appeal is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Db Power Limited, Acit, Central Circle-1, बनाम/ Office Block, 1A, Bhopal Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Assessee/Appellant) (Revenue/Respondent) Acit, Central Circle-1, M/S Db Power Limited, बनाम/ Bhopal Office Block, 1A, Vs. Db City Park, 5Th Floor, Corporate Block, Opp. M.P. Nagar Zone-1, Arera Hills, Bhopal (Pan:Aaccd5475F) (Revenue/Appellant) (Assessee/Respondent)

e) That, without prejudice to the above, the learned CIT(A) grossly erred, both on facts and in law, in upholding the AO's allegation of bogus payments to vendors, merely on the basis of certain excel sheets recovered from some personal email correspondence by one of the ex-employees of the appellant company, without considering and appreciating the material