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

133/- made under Section 14A of the Income Tax Act, 1961 (’the Act’) read with Rule 8D of Income Tax Rules, 1962 (’the Rules’) 2. That on the facts and circumstances of the case and in law, satisfaction recorded under section 14A(2) of the Act was improper and otherwise bad in law and as such, no disallowance

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

section 147 of the Act and, thereafter, concluded that the losses obtained by the assessee on NMCE platform were contrived CO Nos.2 to 4/Ind/2022 losses and those losses were incurred by executing the synchronized trades dealing in illiquid commodities only. He also alleged that the losses were incurred with a specific intention to reduce taxable income by setting

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

section 147 of the Act and, thereafter, concluded that the losses obtained by the assessee on NMCE platform were contrived CO Nos.2 to 4/Ind/2022 losses and those losses were incurred by executing the synchronized trades dealing in illiquid commodities only. He also alleged that the losses were incurred with a specific intention to reduce taxable income by setting

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

section 147 of the Act and, thereafter, concluded that the losses obtained by the assessee on NMCE platform were contrived CO Nos.2 to 4/Ind/2022 losses and those losses were incurred by executing the synchronized trades dealing in illiquid commodities only. He also alleged that the losses were incurred with a specific intention to reduce taxable income by setting

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

133(6) of the Income Tax Department, that the assessee\ncompany could not submit details/documents as per Section \"C\" of DSIR\nguidelines, for A.Y. 2018-19 (F.Y. 2017-18) by 31/10/2018 and therefore file\ncould not be processed for issuing report in Form 3CL by DSIR to the Principal\nChief Commissioner of Income tax or Chief Commissioner of Income

ACIT CENTRAL-2, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

section 40A(2)(b). observed that the appellant has interest related @ 18% whereas to other parties 12% accordingly allowed the paid related parties 12% and disallowed the (ACIT vs. Sarthak Innovation (P) Ltd. remaining interest. The appellant submitted had borrowed funds from banks and parties purpose of development its township project on which total interest

DCIT CENTRAL-1, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

section 40A(2)(b). observed that the appellant has interest related @ 18% whereas to other parties 12% accordingly allowed the paid related parties 12% and disallowed the (ACIT vs. Sarthak Innovation (P) Ltd. remaining interest. The appellant submitted had borrowed funds from banks and parties purpose of development its township project on which total interest

ACIT CENTRAL-2, INDORE vs. SARTHAK INNOVATION (P) LTD., INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

section 40A(2)(b). observed that the appellant has interest related @ 18% whereas to other parties 12% accordingly allowed the paid related parties 12% and disallowed the (ACIT vs. Sarthak Innovation (P) Ltd. remaining interest. The appellant submitted had borrowed funds from banks and parties purpose of development its township project on which total interest

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

disallowance of claim of INR 72,992/- under section 10AA of the Act on the interest earned from fixed deposits kept with bank(s) by the Appellant as margin money for providing letter of credit and guarantee to the suppliers and other Government departments for registration like Sales Tax etc. 8. Deduction in respect of 'Education Cess on income

DEPUTY COMMISSIONER OF INCOME TAX - 3(1), INDORE vs. SHRI RAJEEV AJMERA, INDORE

In the result, the appeal of Revenue is partly allowed for statistical purposes

Bench: Ms.Suchitra Kamble & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2010-11 Dcit-3(1) Shri Rajeev Ajmera, Indore बनाम/ Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Co No.23/Ind/2018 (Arising Out Of Ita No.51/Ind/2018) Assessment Year: 2010-11 Shri Rajeev Ajmera, Dcit-3(1) Indore Indore बनाम/ Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Abgpa4930L Assessee By Shri Mahendra Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.08.2022 Date Of Pronouncement 31.08.2022 आदेश/ O R D E R

section 133(6) of the IT Act, to the ADIT(Investigation).Therefore, in the light of the confirmations and subsequent verification done along with the above judicial decisions and taking into account the totality of the facts and circumstances of the case, there is found to be no basis to doubt the genuineness of payments of commission / brokerage

THE DCIT1(1), INDORE vs. SHRI RAVI ARORA, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2011-12 Dcit-5(1), Shri Ravi Arora, Indore 1007, Khatiwala Tank, बनाम/ 236, Indraprasth Tower, 6, M.G. Road, Vs. Indore. (Revenue / Appellant) (Assessee / Respondent) Pan: Agdpa8921H Assessee By Shri Yash Kukreja, Ca & Shri Hitesh Chimnani, Adv & Ld. Ars Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 04.05.2023 Date Of Pronouncement 31.07.2023

133(6) was received by them. The Assessing Officer noted that the notices were despatched at the addresses given by Page 11 of 37 DCIT v. Ravi Arora Assessment year 2011-12 the assessee and, therefore, the contention of the assessee is rejected. Therefore, the Assessing Officer made addition of Rs.2,30,00,000/- and disallowed the interest payment

SHRI MAYUR BANSAL,GWALIOR vs. THE DCIT, CENTRAL, BHOPAL

In the result, appeals of the revenue in IT(SS)ANo

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

disallowances in assessment framed U/s 153A of the Act, the Id. CIT(A) should have held that none of the addition made are sustainable in the present case. 2.1 BECAUSE assessment order dated 20.12.2019 was issued manually i.e. without Document Identification Number (in short 'DIN'), accordingly, the same was liable to be held as invalid and deemed to have never

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

RITU MITTAL,BURHANPUR vs. ITO BURHANPUR, BURHANPUR

In the result, all grounds raised by the assessee(s) are allowed and appeals filed by the assessee in ITANo

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2015-16

disallowance; if any, shall automatically follow suit as a necessary corollary. No other argument has been raised before us during the course of hearing. This assessee’s latter appeal ITA No. 775/Kol/2018 is allowed.” [emphasis supplied] Smt. Neelam Mittal & Anr ITA No.434 & 435/Ind/2019 16. Further this tribunal in the case of Aditya Mundra vs. Pr. CIT (supra) has also dealt

NEELAM MITTAL,BURHANPUR vs. ITO BURHANPUR, BURHANPUR

In the result, all grounds raised by the assessee(s) are allowed and appeals filed by the assessee in ITANo

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Royassessment Year 2015-16

disallowance; if any, shall automatically follow suit as a necessary corollary. No other argument has been raised before us during the course of hearing. This assessee’s latter appeal ITA No. 775/Kol/2018 is allowed.” [emphasis supplied] Smt. Neelam Mittal & Anr ITA No.434 & 435/Ind/2019 16. Further this tribunal in the case of Aditya Mundra vs. Pr. CIT (supra) has also dealt

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

disallowing said payments under section 40A (3)- Whether on facts, impugned revisional order did not require any interference- Held, yes [Para-16] [ In favour of revenue] 4.0 Therefore, in view of the above discussion I am of the considered opinion that the order dated: 06.01.2016 for A.Y. 2013-14 is erroneous in so far as it is also prejudicial

BHAGWAN SINGH GOUR RUNNING AASHIRWAD FUEL POINT,VILLAGE NEEMKHEDI POST RUNAHA vs. ITO- 4 (3) CV R JAYA KUMAR, INCOME TAX DEPARTMENT OFFICE OF ITO

In the result, Ground No. 2 of the assessee’s appeal is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

disallowance was made by the Assessing Officer under Section 69 of the Act (unexplained investment) was that after the date of demonetization, the assessee being a privately run petrol pump was not eligible to accept SBNs (Specified Bank Notes). Before us, the Counsel for the assessee submitted that the assessee was under a genuine impression that even privately run petrol

JASTEJ GOROWARA,BHOPAL vs. COMMISSIONER OF INCOME-TAX (APPEALS), DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

disallowance made by the learned A.O. and confirmed by Learned CIT(A) be held to be high and unreasonable and be suitably reduced. 3. The appellant craves leave to add, mend or alter any Ground of Appeal before or during the course of appellate proceedings.” First we shall deal with ITA No. 276/Ind/2025 (A.Y. 2011-12) 3. The brief facts