M/S H.K. KALCHURI EDUCATION TRUST,BHOPAL vs. THE ACIT 2(1), BHOPAL

Appeals of the assessees are allowed

Bench: Shri D.T. Garasia, Hon’Ble & Shri O.P. Meena, Hon’Blea.Y. 2011-12 H.K. Kalchuri Education Trust, Bhopal Pan – Aaath 3738 E ::: Appellant

section 13(1)(c)(ii) r.w.s. 13(2)(b) r.w.s. 13(3) and thus the assessee is fully eligible for exemption u/s.11 & 12 of the I.T. Act. 7. That on the facts and in the circumstances of the case and in law, the ld.CIT(A) erred in sustaining the following additions/disallowances. Such additions/disallowances are wholly unlawful and injudicious hence

M/S HAI HAY KSHATRIYA EDUCATION SOCIETY,BHOPAL vs. THE ACIT 2(1), BHOPAL

Appeals of the assessees are allowed

Bench: Shri D.T. Garasia, Hon’Ble & Shri O.P. Meena, Hon’Blea.Y. 2011-12 H.K. Kalchuri Education Trust, Bhopal Pan – Aaath 3738 E ::: Appellant

section 13(1)(c)(ii) r.w.s. 13(2)(b) r.w.s. 13(3) and thus the assessee is fully eligible for exemption u/s.11 & 12 of the I.T. Act. 7. That on the facts and in the circumstances of the case and in law, the ld.CIT(A) erred in sustaining the following additions/disallowances. Such additions/disallowances are wholly unlawful and injudicious hence

M/S RISHIRAJ MEMORIAL EDUCATION & WELFARE SOCIETY,BHOPAL vs. THE ACIT 2(1), BHOPAL

Appeals of the assessees are allowed

Bench: Shri D.T. Garasia, Hon’Ble & Shri O.P. Meena, Hon’Blea.Y. 2011-12 H.K. Kalchuri Education Trust, Bhopal Pan – Aaath 3738 E ::: Appellant

section 13(1)(c)(ii) r.w.s. 13(2)(b) r.w.s. 13(3) and thus the assessee is fully eligible for exemption u/s.11 & 12 of the I.T. Act. 7. That on the facts and in the circumstances of the case and in law, the ld.CIT(A) erred in sustaining the following additions/disallowances. Such additions/disallowances are wholly unlawful and injudicious hence

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

B. Another ground of the appellant is regarding cancellation of registration based on the applicability of provision of section 13(1 )( c), retrospective cancellation of registration by application of provisions of section 12AA( 4) and on applicability of section 12AA(3). In regard to the above, the appellant has resorted to different grounds which are as under

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

B. Another ground of the appellant is regarding cancellation of registration based on the applicability of provision of section 13(1 )( c), retrospective cancellation of registration by application of provisions of section 12AA( 4) and on applicability of section 12AA(3). In regard to the above, the appellant has resorted to different grounds which are as under

ACIT-2(1), UJJAIN, UJJAIN vs. M/S RUCHI J OIL PVT. LTD,, MUMBAI

In the result, Revenue’s appeal ITANo

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year: 2014-15

13 M/s. Ruchi J. Oil Pvt. Ltd. And where the aggregate of such transactions entered into by the assessee in the previous year exceeds a sum of five crore rupees.” 4.5 There are two cumulative conditions for attracting the provisions of clause (i) of section 92BA. These are -- (i) there has to be an expenditure in respect of which payment

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

disallowance of interest on 7 Asian Business Connection Private Limited TDS of Rs. 60,43,900/- were made and the income was assessed at Rs. 2,97,16,45,750/-. 6. Aggrieved assessee preferred appeal before Ld. CIT(A) and failed to succeed on any of the grounds raised before him, as the observations of the Ld. A.O were duly

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

disallowed the above claim made by the appellant stating that the activity of the appellant cannot be termed as manufacture or production as required by the provisions of section 32(1)(iia) and 32AC of the Income Tax Act, 1961 by relying heavily upon the judgment of Hon'ble Supreme Court in the case of NC Budhraja reported

ADIM JATI SEWA SAHKARI SAMITI MYDT JOBAT,ALIRAJPUR vs. FACELESS ASSESSMENT OFFICER, ALIRAJPUR

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiadim Jati Sewa Sahkari Samiti National Faceless बनाम/ Mydt., Assessment Centre Vs. 01, Jobat, Jobat, Delhi Alirajpur (Assessee/Appellant) (Revenue/Respondent) Pan: Aaala0577E Assessee By Shri P.D. Nagar, Ar Revenue By Shri Ashish Porwal, Sr. Dr

disallowing the interest income earned by the assessee by way of FD investment in other Co-op. Society, i.e. Gujarat State Co-op. Bank Ltd. (GSCB) and the rental income from HUDCO and SHARK Systems, which were claimed by the assessee u/s 80P(2)(d) of the Act. Page 8 of 34 Adim Jati Sewa Sahkari Samiti Mydt. 4. Aggrieved

SHRI SURENDRA SINGH BHATIA,INDORE vs. THE JCIT-3, INDORE

In the result, assessee’s appeal is allowed

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

13. In the above background, it is submitted that since I have duly complied with all the conditions as contemplated under the provisions of sub-section (2) of section 271AAA of the income- Tax Act, 1961, the provisions of sub section (1) of section 271AAA, which provides for imposition of penalty in the case of a person in whose

M/S MADHYA PRADESH MADHYAM,BHOPAL vs. THE ACIT, BHOPAL

In the result, both the appeals of the assessee i

Bench: Shri Kul Bharat & Shri Manish Borad

disallowances. Thus, ground nos. 1 to 5 are allowed. 10. Apropos ground No.6, the Ld. counsel for the assessee submitted that Ld. CIT(A) has not adjudicated this ground, therefore, we deem it proper that the issue be restored to the AO to verify the claim of the assessee in respect of credit of TDS. In case

M/S MADHYA PRADESH MADHYAM,BHOPAL vs. THE ACIT 1(2), BHOPAL

In the result, both the appeals of the assessee i

Bench: Shri Kul Bharat & Shri Manish Borad

disallowances. Thus, ground nos. 1 to 5 are allowed. 10. Apropos ground No.6, the Ld. counsel for the assessee submitted that Ld. CIT(A) has not adjudicated this ground, therefore, we deem it proper that the issue be restored to the AO to verify the claim of the assessee in respect of credit of TDS. In case

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

b) The impugned notice lacks jurisdiction as it is hit by limitation prescribed by sub-section (2) of Section 263. It was contended by the Assessee that under Section 263(2), the impugned notice ought to have been issued within two years from the end of the financial year in which the order sought to be revised was passed

INDORE SAHAKARI DUGDH SANGH MARYADIT,DAIRY COMPOUND, MANGLIA vs. COMMISSIONER OF INCOME TAX (APPEALS), NFAC, INCOME TAX DEPARTMENT, DELHI

In the result, the appeals of the assessee are allowed

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

13 it has been held that: What section 80P(2)(d) of the Act......envisages is that such interest or dividend eamed by the assessee co-operative society should be out of the investments with any other co-operative society. The words "Co-operative Banks" are missing in clause (d) of sub-section (2) of section

INDORE SAHAKARI DUGDH SANGH MARYADIT,DAIRY COMPOUND, MANGLIA vs. COMMISSIONER OF INCOME-TAX (APPEALS), NFAC, INCOME TAX DEPARTMENT, DELHI

In the result, the appeals of the assessee are allowed

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

13 it has been held that: What section 80P(2)(d) of the Act......envisages is that such interest or dividend eamed by the assessee co-operative society should be out of the investments with any other co-operative society. The words "Co-operative Banks" are missing in clause (d) of sub-section (2) of section

MP STATE COOPERATIVE DAIRY FEDERATION LIMITED,BHOPAL vs. ACIT BHOPAL, BHOPAL

In the result, the appeal for A

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

b) …………………………………………….. (c) …………………………………………….. (d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income;” On a perusal of Sec. 80P(2)(d), it can safely be gathered that interest income derived by an assessee co-operative society from its investments

MP STATE CO-OPERATIVE DAIRY FEDERATION LIMITED,BHOPAL vs. ACIT, BHOPAL

In the result, the appeal for A

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

b) …………………………………………….. (c) …………………………………………….. (d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income;” On a perusal of Sec. 80P(2)(d), it can safely be gathered that interest income derived by an assessee co-operative society from its investments

SANKALP SAKH SAHKARI SANSTHA MARYADIT,MANDSAUR vs. THE PCIT-1 , INDORE

In the result, appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisankalp Sakh Sahkari Pr. Cit-1 Sanstha Maryadit Indore 1, C/O Smriti Nagrik Sahkari Vs. Bank Dayamandir Road Goshala Market, Mandsaur (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeas0312G Assessee By Shri Anil Kamal Garg, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 25.01.2024 Date Of Pronouncement 30.01.2024

disallowed the claim of deduction u/s 80P(2)(d) of the Act in respect of the interest income received by the assessee on the fixed deposit made with Bhopal Co-operative Central Bank on the ground that the only interest or dividend received on the investment made with the other Co-operative Society is eligible for deduction u/s 80P(2