M/S. CHARITRA GOLD PVT. LTD.,RATLAM vs. THE PR. CIT, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

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

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI ADITYA MUNDRA,DEWAS vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

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

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI MANISH MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

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

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI GOVIND DAS MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

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

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI MANOJ MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

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

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

u/s 263 of the Act. Ld. Pr. CIT again invoked the provision of section 263 vide notice dated 23.03.2020 as well as dated 09.02.2021 on the issue of interest on income tax which was not disallowed by the ld. AO. Ld. AR has submitted that the second revision

M/S RANA & JOSHI BUILDTECH P LTD,INDORE vs. THE PCIT-1, BHOPAL

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Rana & Joshi Buildtech Pr. Cit-1 Pvt. Ltd. Bhopal (Formerly Known As M/S Rana Buildtech Pvt. Ltd. ) Vs. 218 Civil Lines, Below Dainik Bhaskar Office Vidisha (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcr9858P Assessee By Shri S.N. Agrawal Ar Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 11.09.2024 Date Of Pronouncement 26 .09.2024

revision order has also been challenged in appeal before the CIT(A). Further the assesse also challenged penalty order passed u/s 271E by filing the appeal before the CIT(A) within the period of limitation. All these facts and circumstances show that the assesse was very prompt in taking necessary steps for filing the appeal whenever it is advised

M/S RADHISHWARI DEVLOPERS P LTD,INDORE vs. PR CIT -2 INDORE, INDORE

In the result, Assessee’s appeal in ITANo

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing Assessment Year 2013-14 M/S. Radhishwari Developers P. Ltd. (Now Known As R.C. Warehousing Pvt. Ltd. ) Indore : Appellant Pan :Aafcr1916A V/S Pr. Cito-2 : Respondent Indore Appellant By S/Shri Sumit Nema Sr. Adv. With Gagan Tiwari & Piyush Parashar Advs. Revenue By Shri S.S. Mantri, Cit-Dr Date Of Hearing 24.05.2021 Date Of Pronouncement 20.07.2021

u/s 263: Case laws on the power of Commissioner, favour Revenue, in folloiwng situations as regards enquiry by Assessing Officer : a. Complete failure to conduct relevant enquiry. b. Conducting enquiry but not taking it to its logical conclusion. c. Conducting enquiry but drawing the wrong conclusion. 6.1 Reference is invited to recent judgement of Kolkata Tribunal in the case

GAURANG METALS P LTD,INDORE vs. THE PCIT-1, INDORE

Bench: Shri Chandra Mohan Garg & Shrib.M. Biyaniassessment Year: 2017-18 Gaurang Metals Pvt. Ltd. Pr. Cit-1 बनाम/ Indore Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aabcg2498Q Assesseeby Shri S.N. Agrawal & Shri Pankaj Mogra, Ars Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 18.11.2022 Date Of Pronouncement 20.01.2023

disallowance as per provisions of section 14A. 7. Aggrieved by such revision-order, the assessee has filed this appeal. 8. By means of various grounds raised in the Appeal Memo which are not being reproduced for the sake of brevity, the appellant-assessee requires us to adjudicate whether or not the revision-order passed by Ld. PCIT u/s 263

M/S ROCKBED RENOVATORS LTD.,BHOPAL vs. THE PCIT-1, BHOPAL

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanirockbed Renovators Ltd. Pr. Cit-1 7-A, Panjabi Bagh Raisen Road Bhopal Govindpura Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacr7151G Assessee By Shri Gagan Tiwari Ar Revenue By Ms. Ila Parmar, Cit- Dr Date Of Hearing 10.06.2024 Date Of Pronouncement 12.06.2024

revision order dated 28.03.2023 of Pr. Commissioner of Income Tax, Bhopal passed u/s 263 of the Act for Assessment Year 2018-19. The assessee has raised following grounds of appeal : “1. That the order of the Ld. Pr. Commissioner of Income Tax, Bhopal u/s 263 of the Act is illegal, void and without jurisdiction. 2. That the Ld. Pr. Commissioner

SHRI JANKILAL,UJJAIN vs. PCIT-1, INDORE

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2017-18 Jankilal Pr.Cit-1 बनाम/ 12, Chimanganj Mandi Indore Agar Road, Ujjain Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aczpj 2632 A Assessee By Shri Manoj Fadnis, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 08.02.2023 Date Of Pronouncement 18.04.2023

263 of the act. 5. By the aforesaid show-cause notice, the assessee was asked to explain as to why the assessment-order may not be revised. In response thereto, the assessee made a detailed submission to Ld. PCIT which is re-produced in Para No. 3 of the revision-order. 6. However, none of those submissions impressed

M/S. S.R. FERRO ALLOYS,JHABUA vs. THE PCIT, BHOPAL

In the result, the appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

263 of the Act. In such matters, to remand the matter/issue to the Assessing Officer would imply and mean the CIT has not examined and decided whether or not the order is erroneous but has directed the Assessing Officer to decide the aspect/question. 17. This distinction must be kept in mind by the CIT while exercising jurisdiction under Section 263

RAJKUMAR GOYAL,INDORE vs. THE PR. CIT-2, INDORE

In the result, appeal of the assesse is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniraj Kumar Goyal Pr. Cit-2 42, Narmda Marg Barwaha Indore Vs. Khargone (Appellant / Assessee) (Revenue) Pan: Ackpg 1896N Assessee By Shri Ram Gilda, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.09.2023 Date Of Pronouncement 20.11.2023

u/s 263 on the basis of the proposal and suggestion of AO shows that the Pr. CIT has not taken an independent decision by application of mind on the assessment record but it is a borrowed satisfaction. He has submitted that the assessee accepted first disallowance of Rs.90,022/- and the same may be rectified as per the provisions

INFOBEANS TECHNOLOGIES LIMITED,INDORE, M.P. vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, INDORE - 1, INDORE, M.P.

In the result, the appeal filed by the assessee is dismissed being devoid of

Bench: Sh. Bhagirath Mal Biyani & Sh. Udayan Dasgupta

disallowance u/s 14A will be NIL and in such cases the twin conditions for assumption of jurisdiction under section 263 are not satisfied. 12 I.T.A. No.371/Ind/2024 Infobeans Technologies Ltd. v. PCIT 17. He further submitted that the above facts clearly establish that the ld. Commissioner has travelled beyond jurisdiction vested upon him u/s 263 and has stepped into shoes

MAA NARMADA AGROTECH AND INFRASTURES LTD,INDORE vs. THE PCIT-1 , INDORE

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimaa Narmada Agrotech & Pcit Infrastructures Limited Indore -1 Ug-47, Trade Centre, Vs. Kanchan Bagh Main Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcm6285 P Assessee By Shri S.N. Goyal & Shri Pranay Goyal, Ars Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 31.05.2023 Date Of Pronouncement 11.07.2023

revision order u/s 263 of the Act. The sole ground for setting aside the order passed by the AO is lack of inquiry on the part of the AO in respect of these issues. However, we find that the AO issued show cause notice u/s 142(1) and specifically asked the assessee to furnish details and evidence in respect

MADHYA PRADESH VIDYUT MANDAL KARMCHARI PARASPAR SAHAKARI SANSTHA MARYADIT,MANDSAUR vs. PCIT INDORE-1, INDORE

In the result, we reject condonation request of assessee and consequently this appeal filed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshimadhya Pradesh Vidyut Pr. Cit-1, बनाम/ Mandal Karmchari Indore Vs. Paraspar Sahakari Sanstha Maryadit, Shop No.5 Nahar Sayyad Road, Kityani Mandsaur (Assessee/Appellant) (Revenue/Respondent) Pan:Aaaam6716A Assessee By Shri Ashok Ratnawat, Ar Revenue By Shri Anoop Singh, Cit-Dr Date Of Hearing 10.11.2025 Date Of Pronouncement 11.11.2025

revision u/s 263. 3. That the learned PCIT failed to appreciate that the appellant is a co- operative society entitled to deduction u/s 80P of the Income Tax Act, 1961, and even otherwise, the disallowance

SAHARAYN UNIVERSAL MULTIPURPOSE SOCIETY LIMITED,BHOPAL vs. THE COMMISSIONER OF INCOME TAX (APPEALS), BHOPAL

Appeal is allowed for statistical purposes

u/s 139(5) of the Act. The finding\nof the CIT(A) are given at Para 9.1 of his order.\nIt is settled law that any legal claim can be made at any time by the appellant before the\nappellate authorities and for this, the assessee rely on the following cases:-\n1. CIT vs. Jai Parabolic Springs

M/S M.P.WAREHOUSING & LOGISTIC CORPORATION,BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, the appeal is allowed

Bench: Ms. Suchitra Kamble & Shri B.M. Biyaniassessment Year: 2015-16 M/S M.P. Warehousing Pr. Cit-1 & Logistic Corporation, Bhopal बनाम/ Office Complex, Block-1, Gautam Nagar, Vs. Bhopal (Appellant / Assessee) (Respondent / Revenue) Pan: Aadcm 7742 B Assessee By Shri S.S. Deshpande, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 20.03.2023 Date Of Pronouncement 31.03.2023

revision-order dated 19.03.2021 passed by learned Pr. Commissioner of Income-Tax-1, Bhopal [“Ld. PCIT”] u/s 263 of Income-tax Act, 1961 [“the Act”], which in turn arises out of assessment-order dated 16.06.2017 passed by learned ACIT-2(1), Bhopal [“Ld. AO”] u/s 143(3) for Assessment-Year [“AY”] 2015-16, the assessee has filed this appeal