THE ADDL. CIT RANGE -1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

disallowance u/s 68 of the Act pertaining to accommodation entry received by the assessee through shell entities and has also paid commission to the intermediaries @ 1%. The ld. CIT-DR submitted that the AO made addition by considering the statement of Director of Mega Money Commodities Pvt. Ltd. (MMCPL) which was deleted by the ld.CIT(A) without any basis. Therefore

THE ACIT,CENTRAL-1, INDORE vs. M/S PRAKASH OILS LTD., DHAR

In the result, the above captioned appeals filed by the Revenue as well as the

Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani

disallowance u/s 68 of the Act pertaining to accommodation entry received by the assessee through shell entities and has also paid commission to the intermediaries @ 1%. The ld. CIT-DR submitted that the AO made addition by considering the statement of Director of Mega Money Commodities Pvt. Ltd. (MMCPL) which was deleted by the ld.CIT(A) without any basis. Therefore

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

10B(4) of the Income Tax Rules, 1962 (‘the Rules’) which authoress abusage of multiple year data of comparable companies for the purpose of determination of the ALP under section 92F of the Act. 4.4 Rejecting the comparable companies identified by the appellant in its transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant

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

10B(4) of the Income Tax Rules, 1962 (‘the Rules’) which authoress abusage of multiple year data of comparable companies for the purpose of determination of the ALP under section 92F of the Act. 4.4 Rejecting the comparable companies identified by the appellant in its transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant

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

10B(4) of the Income Tax Rules, 1962 (‘the Rules’) which authoress abusage of multiple year data of comparable companies for the purpose of determination of the ALP under section 92F of the Act. 4.4 Rejecting the comparable companies identified by the appellant in its transfer pricing study. 4.5 conducting fresh search by rejecting the objections raised by the appellant

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

disallowing expenditure towards earning of such income, under section 14A, whereas, no expenditure was in fact incurred by the assessee towards earning such income. 25. The ld. AO has erred in computing interest u/s 234B of the Act on the assessed income since the addition to the returned income on account of Transfer Pricing adjustment is only a notional income

DCIT-4(1), INDORE, INDORE vs. MARAL OVERSEAS LTD, KHARGONE

In the result appeal of Revenue is dismissed

Bench: Shri B.M. Biyani & Shri Paresh M Joshidcit-4(1), Indore Maral Overseas Ltd., बनाम/ Maral Sarovar, V& Po Vs. Khalbujurg, Kasrawad, Khargone, Bhopal

10B as per para-3 Rs. 1,16,32,645/ 2. Disallowance out of Business Promotion Expenses as per para-4 Rs. 1,00,000/- Difference on accounts as per para - 5 Rs. 16,131/- 4. Unsecured loans as per para - 6 Rs. 30,000/- 5. Gratuity claim u/s 40A(7) as per para

M/S. FLEXITUFF INTERNATIONAL LTD.,DHAR vs. THE PR.CIT-1, INDORE

In the result appeal of the assessee is partly allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2012-13 M/S. Flexituff International Pr. Commissioner Of Ltd, Vs. Income Tax-1, C-41-50, Sez, Sector-3, Indore Pithampur, Dist. Dhar (Appellant) (Respondent ) Pan Aaacn5986H Revenue By Smt. Ashima Gupta, Cit Assessee By Shri Manjit Sachdeva & Avinash Gaur, Advocates Date Of Hearing 26.03.2019 Date Of Pronouncement 14.05.2019 O R D E R

2(45) has no application to the computation under Section l0A and the reference therein is only to the total income of the eligible unit/undertaking. The provisions of Section 10A(6), as amended by Finance Act of 2003 retrospectively with effect from 1.4.2001, has also been stressed upon to contend that with effect from the assessment year 2001-02 losses

SHRI DANDI SEWA ASHRAM,ONKARESHWAR vs. INCOME TAX OFFICER EXEMPTION , BHOPAL

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

section 253 of the income tax Act 1961,[ herein after referred to as the Act for the sake of convenience & brevity] before this tribunal as and by way of a second appeal. The Assessee is aggrieved by the order bearing Number:-ITBA/NFAC/S/250/2024- 25/1065627607(1) dated 13/06/2024 passed by the Ld. CIT (A) u/s 250 of the Act, which is herein

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ADDL. CIT-RANGE-3, BHOPAL

In the result, appeal for A

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

disallowance of expenses of Rs. 42,65,430 towards expenses of Power & Fuel . 4.The appellant craves leave to add, to alter and/or to modify the grounds of appeal on or before the date of hearing.” 2. Ground no.1 is regarding validity of reopening of the assessment. 2.1 Ld. AR of the assessee has submitted that the assesse is engaged

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ACIT-3(1), BHOPAL

In the result, appeal for A

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

disallowance of expenses of Rs. 42,65,430 towards expenses of Power & Fuel . 4.The appellant craves leave to add, to alter and/or to modify the grounds of appeal on or before the date of hearing.” 2. Ground no.1 is regarding validity of reopening of the assessment. 2.1 Ld. AR of the assessee has submitted that the assesse is engaged

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

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

disallowance of expenses of Rs. 42,65,430 towards expenses of Power & Fuel . 4.The appellant craves leave to add, to alter and/or to modify the grounds of appeal on or before the date of hearing.” 2. Ground no.1 is regarding validity of reopening of the assessment. 2.1 Ld. AR of the assessee has submitted that the assesse is engaged

PROF. RAJENDRA SINGH SHIKSHAN SAMITI,MANDSAUR vs. DCIT, CPC BENGALURU AND ITO, EXEMPTION, UJJAIN, UJJAIN

The appeal of the assessee is allowed

Bench: Shri B.M. Biyani & Shri Udayan Das Guptaassessment Year:2019-20 Prof. Rajendra Singh Dcit, Cpc Gangaluru Shikshan Samiti, Mandsaur बनाम/ Saraswati Shishu Mandir Vs. Keshav Nagar (Assessee/Appellant) (Revenue/Respondent) Pan: Aaeap0905C Assessee By Shri Apurva Mehta & Rajesh Mehta, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 20.01.2025 Date Of Pronouncement 31.01.2025

disallowed by the AO for not filing of form 10 within the specified period. 5.1 The matter was carried in appeal before the Ld. J CIT(A) and it is seen from the order of the First Appellate Authority that the assessee has not filed any written submission or explanations before the Ld. JCIT(Appeals) in spite of notice

M/S ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS V A TECH HYDRO INDAI PVT. LTD.),MANDIDEEP vs. THE ACIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

10B(1)(a) e) questioning the commercial rationale of the legitimate business expense incurred by the taxpayer and not restricting the scope of assessment under section 92CA to determining the arm`s length price of international transactions by adopting one of the prescribed method only. 4. The DRP also erred in issuing directions with certain typographical errors, which denied

THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

10B(1)(a) e) questioning the commercial rationale of the legitimate business expense incurred by the taxpayer and not restricting the scope of assessment under section 92CA to determining the arm`s length price of international transactions by adopting one of the prescribed method only. 4. The DRP also erred in issuing directions with certain typographical errors, which denied

M/S. ANDRITZ HYDRO PRIVATE LIMITED (EARLIER KNOWN AS VA TECH HYDRO INDIA PRIVATE LIMITED),BHOPAL vs. THE DCIT 1(1), BHOPAL

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

10B(1)(a) e) questioning the commercial rationale of the legitimate business expense incurred by the taxpayer and not restricting the scope of assessment under section 92CA to determining the arm`s length price of international transactions by adopting one of the prescribed method only. 4. The DRP also erred in issuing directions with certain typographical errors, which denied

THE DCIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

10B(1)(a) e) questioning the commercial rationale of the legitimate business expense incurred by the taxpayer and not restricting the scope of assessment under section 92CA to determining the arm`s length price of international transactions by adopting one of the prescribed method only. 4. The DRP also erred in issuing directions with certain typographical errors, which denied

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-II, BHOPAL, BHOPAL vs. M/S AGRAWAL CONSTRUCTION CO., BHOPAL

Bench: Shri Manish Borad & Mis Madhumita Royvirtual Hearing It(Ss)A Nos.233 To 238/Ind/2017 Assessment Year:2006-07 To 2011-12 M/S. Agrawal Construction Co. Acit, 1(1) बनाम/ Bhopal Bhopal (Appellant) (Respondent ) Vs. P.A. No.Aaefa8225H It(Ss)A No.224 To 226/Ind/2017 Assessment Year:2009-10 To 2011-12 Acit, 1(1) M/S. Agrawal Construction बनाम/ Bhopal Co. Bhopal Vs. (Appellant) (Respondent ) P.A. No.Aaefa8225H Assessment Year: 2012-13

10B) is prospective in nature and can have no application to a housing project that is approved before 31st March, 2005. As the deduction sought to be claimed under section 80-IB(10) is inseparably linked with the date of approval of the housing project, it would make no difference if the construction of the said project was completed