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

133(6) were issued by the AO to the brokers who duly complied with the same and represented their matters before the then AO. It is further submitted by the appellant that the entire discussion made by the AO in the reassessment order is with respect to brokers namely S. N. Commodities, Shubhlaxmi Commodities, Subhlamxi Traders and Sairam Commodities

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

133(6) but it failed to comprehend the rationale or logic behind.............., nor to examine any of the ....................It is highly improbable for any person having sound mind to purchase at arm’s length the shares of a private limited company, hardly having any worth, with face value of Rs.10 at a premium of Rs.190. This mere fact should have

NEMINATH DEVELOPERS,UJJAIN vs. ACIT2(1) , UJJAIN

Appeal is partly allowed in the terms indicated

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year: 2015-16 Neminath Developers, Acit 2(1) 105, Mani Trade Centre, Ujjain बनाम/ Shanku Marg Freeganj, Vs. Ujjain (Assessee/Appellant) (Revenue/Respondent) Pan: Aagfn3566L Assessee By Shri Pavan Ved, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 05.03.2026 Date Of Pronouncement 10.04.2026

section 68, namely identity, creditworthiness and genuineness of transactions, were not verifiable. These observations are primarily based on (i) the manner of posting of replies to notices issued by AO u/s 133(6), and (ii) the low Gross Total Income declared by the creditor-companies. Page 18 of 23 Neminath Developers ITA No. 688/Ind/2025

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

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 under section

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 under section

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

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 under section

THE DCIT, 1(1), INDORE vs. M/S. MODERN LABORATORIES, INDORE

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

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./ ./ ./ I.T.A. No.277 & Co.16/Ind/2014 ./ "नधा"रण वष" /Assessment Year:2008-09

section 133(6) to all commission agents and all of them have confirmed rendering services and receiving commission. The AO disallowed

DY. CIT -1(1), INDORE vs. M/S. AGRAWAL TRANSPORT CORPORATION (P) LTD., INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

disallow Rs 37,536/- (claim this year Rs. 1,57,236/- claimed last year Rs 1,19,700/-) and added to the assessee's total income. 6.14 Thus in this assessment order, the issue of share capital raised by Chamak in AY 2001-05 was specifically examined by issuing summons and not ice s under section 133(6

THE DCIT1(1), INDORE vs. M/S. AVILABLE FINANCE LTD., INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

disallow Rs 37,536/- (claim this year Rs. 1,57,236/- claimed last year Rs 1,19,700/-) and added to the assessee's total income. 6.14 Thus in this assessment order, the issue of share capital raised by Chamak in AY 2001-05 was specifically examined by issuing summons and not ice s under section 133(6

M/S AD-MANUM FINANCE LTD.,INDORE vs. THEDCIT 1(1) , INDORE, INDORE

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2010-11

disallow Rs 37,536/- (claim this year Rs. 1,57,236/- claimed last year Rs 1,19,700/-) and added to the assessee's total income. 6.14 Thus in this assessment order, the issue of share capital raised by Chamak in AY 2001-05 was specifically examined by issuing summons and not ice s under section 133(6

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

6. We have heard the rival submissions made by the respective parties and perused the materials available on record. 7. Before the First Appellate Authority, the assessee submitted as follows: “2. AS REGARDS TO GROUND NO 1 – INVOKING THE PROVISIONS OF SECTION 40A (2)(b). 2.1 The Learned AO erred in disallowing a sum of Rs. 14,50,421/- under

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

6. We have heard the rival submissions made by the respective parties and perused the materials available on record. 7. Before the First Appellate Authority, the assessee submitted as follows: “2. AS REGARDS TO GROUND NO 1 – INVOKING THE PROVISIONS OF SECTION 40A (2)(b). 2.1 The Learned AO erred in disallowing a sum of Rs. 14,50,421/- under

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

6. We have heard the rival submissions made by the respective parties and perused the materials available on record. 7. Before the First Appellate Authority, the assessee submitted as follows: “2. AS REGARDS TO GROUND NO 1 – INVOKING THE PROVISIONS OF SECTION 40A (2)(b). 2.1 The Learned AO erred in disallowing a sum of Rs. 14,50,421/- under

DCIT , CENTRAL -2 , INDORE vs. M/S GREAT GALLEON VENTURES LTD , INDORE

In the result, the appeals of the Revenue bearing ITANo

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad

133(6) of the Act however, Ld AO neither made any independent enquiry subsequent to their filing of Affidavits retracting the statements nor Ld.AO provided any opportunity of cross-examination to the assessee. 13.4 Learned Counsel for the assessee further submitted that during the course of the assessment proceedings, it was submitted before the AO that in respect

DCIT , CENTRAL -2 , INDORE vs. M/S GREAT GALLEON VENTURES LTD , INDORE

In the result, the appeals of the Revenue bearing ITANo

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad

133(6) of the Act however, Ld AO neither made any independent enquiry subsequent to their filing of Affidavits retracting the statements nor Ld.AO provided any opportunity of cross-examination to the assessee. 13.4 Learned Counsel for the assessee further submitted that during the course of the assessment proceedings, it was submitted before the AO that in respect

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

133(6(. The assessee cannot be held liable for the same and consequently cannot be parished by disallowing the claim of expenses which is otherwise supported by the relevant evidences. 3.3 In support of his contention he has relied upon the decision of this tribunal dated 08.02.2024 in case of AL AS Real Estate and Page 7 of 33 ITANo.214/Ind/2023

CHIRAYU CHARITABLE FOUNDATION,BHOPAL vs. PCIT (CENTRAL), BHOPAL

In the result appeal of the assessee stands allowed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradchirayu Charitable Pcit (Central), Foundation,Bhopal Indore Bhopal Highway, Bhaisakhedi, Vs. Bhopal (Appellant) (Revenue ) Pan No.Aaaac3656P Revenue By Shri S.S. Mantri, Cit Appellant By S/Shri Sumit Nema, Sr. Advocate, Gagan Tiwari & Piyush Parashar, Advs Date Of Hearing 05.01.2021 Date Of Pronouncement .02.2021 O R D E R Per Manish Borad, Am.

133(6) of the Act which was Chirayu Charitable Foundation duly complied that the donor have confirmed to have given donation to the assessee. 35. Our finding with regard to the alleged donations received by which prima facie shows that the donors are not fictitious, secondly donors are trust or institutions having sufficient funds to give donations and in some

SOM DISTILLERIES PVT. LTD.,BHOPAL vs. ITO-1(3), BHOPAL

Appeal is partly allowed for statistical

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

Section 145 are applicable. The books of accounts are also not been rejected, hence the adhoc disallowance are wholly unlawful and unjustified. The assessee submits that the disallowance is neither justified nor lawful. From the perusal of the chart, the increase in mainly on account Page 32 of 54 Som Distilleries Private Limited I.T.A. Nos. 272 & 289/Ind/2023