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

144C(5) of the Act. In the directions, the AO observed that the DRP had upheld the disallowance of Rs.6,07,00,658/- made under Section 14A as per rule 8D. Also for upward adjustment of Rs.212,56,79,027/- on account of software services. The DRP confirmed the same. The Assessing Officer vide Assessment Order dated 05.02.2016 made addition

MR.VINEET SHRIVASTAVA,BHOPAL vs. THE ITO ( IT&TP), BHOPAL

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

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimr. Vineet Shrivastava Ito (It & Tp) E-7/795, Arera Colony Bhopal Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Bcxps 2544 H Assessee By Shri Rohit Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.06.2023 Date Of Pronouncement 22.06.2023

section 144C(13) of the Act. 4.Without prejudice of above grounds and in alternate on merits of the case, the Ld. AO erred in disregarding the Fair Market Value (FMV) (as on 01.04.2001) of asset property of INR 28,50,000 and incorrectly computed the FMV (as on 01.04.2001) as INR 5,15,684. 5. Without prejudice of above grounds

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

144C and 92CA of Income Tax Act,1961(hereinafter referred as of ”the Act”) of the Deputy Commissioner of Income tax- 1(1),Bhopal (hereinafter referred as “the AO”), for the assessment year 2010-11 order dated 13.02.2015 and for the A.Y. 2011-12 order dated 22.02.2016 passed in pursuance of the directions issued by Dispute Resolution Panel-IV, Mumbai

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

M/S. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

section 144C(13) in pursuant to the directions of DRP dated 26.12.2016 passed u/s 144C(5) of the Act for Assessment Year 2012-13. 2. The assesse has under gone the liquidation process before the NCLT vide order dated 22.10.2020 the liquidator was appointed by NCLT. Page 1 of 17 Bhatia Global Trading Ltd. Page 2 of 17 3. None

DCIT !(1) INDORE, INDORE vs. AGRAWAL COAL CORPORATION (P) LTD., INDORE, INDORE

In the result all the three appeals of the revenue are

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

144C of the Income Tax Act dated 22.03.2016 framed by the DCIT-1(1), Indore. 2. As the issues raised in the appeals and cross objections are common in nature these were heard together and are being disposed off by this consolidated order for the sake of time and brevity. 3. First we will take up Revenue’s appeal raising

DEPUTY COMMISSIONER OF INCOME TAX 1 (1), INDORE vs. M/S AGRAWAL COAL CORP. PVT. LTD., INDORE

In the result all the three appeals of the revenue are

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

144C of the Income Tax Act dated 22.03.2016 framed by the DCIT-1(1), Indore. 2. As the issues raised in the appeals and cross objections are common in nature these were heard together and are being disposed off by this consolidated order for the sake of time and brevity. 3. First we will take up Revenue’s appeal raising

M/S AGRAWAL COAL CORP. PVT. LTD.,INDORE vs. DEPUTY COMMISSIONER OF INCOME TAX 1, INDORE

In the result all the three appeals of the revenue are

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

144C of the Income Tax Act dated 22.03.2016 framed by the DCIT-1(1), Indore. 2. As the issues raised in the appeals and cross objections are common in nature these were heard together and are being disposed off by this consolidated order for the sake of time and brevity. 3. First we will take up Revenue’s appeal raising

DEPUTY COMMISSIONER OF INCOME TAX 1, INDORE vs. M/S AGRAWAL COAL CORP. PVT. LTD., INDORE

In the result all the three appeals of the revenue are

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

144C of the Income Tax Act dated 22.03.2016 framed by the DCIT-1(1), Indore. 2. As the issues raised in the appeals and cross objections are common in nature these were heard together and are being disposed off by this consolidated order for the sake of time and brevity. 3. First we will take up Revenue’s appeal raising

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

disallowance u/s 14A. With such disallowances/additions, the AO proposed to determine total income at Rs. 65,98,26,453/-. Against draft- assessment order, the assessee filed objection dated 28.01.2011 to Disputes Resolution Panel (DRP). The DRP passed order dated 08.09.2011 u/s 144C(5) of the act whereby the objections of assessee were turned down and the draft assessment order

RITIKA JAIN,THANE vs. ITO(IT TP), BHOPAL, AAYKAR BHAVAN

Appeal of the assessee is allowed for statistical purpose

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiritika Jain, Cit (Appeals), बना A-504, Laxmi Residency Chs Nfac, म/ Ltd, Delhi Vs. Opposite Datta Mandir Check Naka, Wagle Estate, Thane

disallowed and treated as unexplained investment made in aforesaid immovable Page 5 of 18 Ritika Jain ITA No. 632/Ind/2024 - A.Y.2015-16 property and being added to the total income of the assessee as unexplained investment u/s 69 of the IT Act for A.Y. 2015-16. 2.15 The d. A.O thus made addition of Rs. 10,85,000/- (supra). 2.16 That since

ANDRITZ HYDRO P LTD,BHOPAL vs. PR CIT-1, BHOPAL

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing

144C r.w.s 92CA of the IT Act, 1961 dated 25.01.2018 passed by the DCIT-1(1), Bhopal for A.Y. 2014-15, The assessee company was engaged in the manufacturing of generators and its equipments besides providing installation and erection services. On perusal of the assessment order and case recordd, it is notices that the assessee company debited Rs.30

ACIT (CENTRAL) , UJJAIN vs. M/S. ARIBA FOODS (P) LTD., INDORE

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

144C and u/s 143(3) of the Income Tax Act 1961(In short the ‘Act’) dated 28.12.2018, 27.12.2018 and 26.12.2018 respectively framed by ACIT(Central), Ujjain. 2. Revenue has raised following grounds of appeal :- (i) M/s Ariba Foods Pvt. Ltd ITA No.736/Ind/2019 Assessment Year 2016-17 1.On the facts and in the circumstances of the case

THE ACIT (CENTRAL), UJJAIN vs. M/S. VYANKTESH PLASTICS & PACKAGING (P) LTD., UJJAIN

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

144C and u/s 143(3) of the Income Tax Act 1961(In short the ‘Act’) dated 28.12.2018, 27.12.2018 and 26.12.2018 respectively framed by ACIT(Central), Ujjain. 2. Revenue has raised following grounds of appeal :- (i) M/s Ariba Foods Pvt. Ltd ITA No.736/Ind/2019 Assessment Year 2016-17 1.On the facts and in the circumstances of the case

THE ACIT (CENTRAL), UJJAIN vs. M/S. FAMOUS VANIJYA (P) LTD. , UJJAIN

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

144C and u/s 143(3) of the Income Tax Act 1961(In short the ‘Act’) dated 28.12.2018, 27.12.2018 and 26.12.2018 respectively framed by ACIT(Central), Ujjain. 2. Revenue has raised following grounds of appeal :- (i) M/s Ariba Foods Pvt. Ltd ITA No.736/Ind/2019 Assessment Year 2016-17 1.On the facts and in the circumstances of the case