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 40(a)(ia) does not arise just because here was non-compliance of provisions of section 194C(7). Thus, we are unable to see any valid reason to interfere with the findings of the ld.CIT(A) and, thus, we uphold the same. Accordingly, grounds No. 4 and 5 of the Revenue are also dismissed. CO Nos.2 to 4/Ind/2022

SAHARAYN UNIVERSAL MULTIPURPOSE SOCIETY LIMITED,BHOPAL vs. THE COMMISSIONER OF INCOME TAX (APPEALS), BHOPAL

Appeal is allowed for statistical purposes

19 of 28\nSaharayn Universal Multipurpose Society Limited,\nITA No. 425/Ind/2024 - AY 2015-16\nhimself invoked section 40(a)(ia) and made disallowance

INFOBEANS TECHNOLOGIES LIMITED,INDORE, M.P. vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX, INDORE - 1, INDORE, M.P.

In the result, the appeal filed by the assessee is dismissed being devoid of

Bench: Sh. Bhagirath Mal Biyani & Sh. Udayan Dasgupta

section 263 of Income Tax Act 1961 are required to be invoked. Therefore, the assessment for A.Y. 2018- 19 framed on 15/04/2021 is hereby set-aside to the file of AO to re-examine the issue and to make de-novo assessment, indicated in the preceding discussion, u/s 263 and passing an order as per the law after making necessary

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

disallowed under Section 14A read with Rule 8D. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before us. 5. The Ld. AR submitted that the assessee company was incorporated in India on 13.09.1996. The assessee provides software development and maintenance services from STPI and SEZ registered units. The primary activities of the assessee relate to provision

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

disallowed under Section 14A read with Rule 8D. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before us. 5. The Ld. AR submitted that the assessee company was incorporated in India on 13.09.1996. The assessee provides software development and maintenance services from STPI and SEZ registered units. The primary activities of the assessee relate to provision

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

disallowed under Section 14A read with Rule 8D. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before us. 5. The Ld. AR submitted that the assessee company was incorporated in India on 13.09.1996. The assessee provides software development and maintenance services from STPI and SEZ registered units. The primary activities of the assessee relate to provision

THE ACIT, CIRCLE 2(1), INDORE vs. M/S SURYA INFRA VENTURE PVT. LTD., INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

19,30,429 2 Blasting expenses 13,39,555 3 Site expenses 75,23,136 4 Disallowance under Section 40A(3) of the 8,12,755 Act 5 Employee

THE AIT,ENTRAL-1, INDORE vs. SURYA INFRAVENTURE P LTD, INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

19,30,429 2 Blasting expenses 13,39,555 3 Site expenses 75,23,136 4 Disallowance under Section 40A(3) of the 8,12,755 Act 5 Employee

THE ACIT, CENTRAL-1, INDORE vs. M/S SURYA INFRA VENTURE PVT. LTD., INDORE

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

19,30,429 2 Blasting expenses 13,39,555 3 Site expenses 75,23,136 4 Disallowance under Section 40A(3) of the 8,12,755 Act 5 Employee

THE ACIT, RATLAM vs. M/S DYNAMIC ENTERPRISES, , RATLAM

In the result, the appeal of the revenue is dismissed

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2015-16 Acit-Ratlam M/S. Dynamic Enterprises, 65, बनाम/ Globus Township, Near Indralok Vs. Nagar, Ratlam (Mp) (Revenue) (Respondent) Pan: Aajfd9155C Revenue By Shri K.G. Goyal, Sr. Dr Respondent By Shri Kaide Kangsawala, Ca Date Of Hearing: 19.06.2019 Date Of Pronouncement: 26.06.2019 आदेश / O R D E R Per Manish Borad, A.M: This Appeal By Revenue Pertaining To A.Y. 2015-16 Is Directed Against The Order Of Ld. Commissioner Of Income Tax(Appeals)- Ujjain, (In Short ‘Cit(A)’), Dated 24.04.2018 Which Is Arising Out Of The Order U/S 143(3) Of The Income Tax Act 1961(Hereinafter Called As The ‘Act’) Framed On 26.12.2017 By Acit, Ratlam. The Revenue Has Raised Following Grounds Of Appeal:

disallowance observing as follows: 3 Dynamic Enterprises ITANo.638/Ind/2018 “Ground No.1,2 & 3:- Through these grounds of appeal the appellant has challenged the addition of Rs.14,19,387/- u/s 2(24)(x) of the I.T. Act. The appellant made the above payments before filing of return of income. The above expenditure is allowable expenditure in view of Hon'ble I.T.A.T., Indore

MUDIT KUMAR BAJAJ,UJJAIN vs. ITO-1(2), UJJAIN

In the result, the appeal of the assessee is allowed”

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani(Respondent/ Revenue) Pan: Aezpb2621P Assessee By Ms. Nupur Ladha & Shri Vaibhav Siroliya, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 13.06.2024 Date Of Pronouncement 18.06.2024 O R D E R

19 Mudi Kumar Bajaj (a) The paramount consideration of section 40A(3) is to curb and reduce the possibilities of black money transactions. As held by the Supreme Court in Attar Singh Gurmukh Singh (supra), section 40A(3) of the Act does not eliminate considerations of business expediencies. (b) In the present case, the appellant assessee was compelled to make

ACIT 4(1), INDORE vs. SHRI SATISH JAIN, INDORE

In the result, the appeal of revenue is dismissed and the cross- objection of assessee is allowed

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court)

section 14A was restricted to 1 percent of average investments in terms of Rule 8D of the Act. Thus, in view of the above judicial decisions, this ground of appeal is allowed in favour of appellant and accordingly, the said disallowance u/s 14A of the IT Act is being restricted to 1% of average investments of Rs.1,19

RNG CONSTRUCTION CO.,INDIRA NAGAR vs. DCIT, DCIT-CPC

Appeal is allowed for statistical purpose

Bench: Shri B.M. Biyani & Shri Paresh M. Joshirng Construction Co. Dcit बनाम/ 14, Sector-A, Vs. Indira Nagar, Mandideep (Assessee/Appellant) (Revenue/Respondent) Pan: Aaqfr9084B Assessee By Shri Yashwant Sharma, Ca & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 28.08.2025 Date Of Pronouncement 29.08.2025

19,80,524/-] and (ii) Disallowance of Rs. 25,25,299/- u/s 43B for non- payment of Service-tax of Rs. 25,10,511/- and Professional tax of Rs. 14,788/- by due date for filing of return u/s 139(1). Aggrieved, the assessee 2nd carried matter in first-appeal for item of disallowance

JARNALBEER SINGH BHATIA,KHANDWA vs. THE ACIT CENTRAL-3, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

section 194C(7) disallowance u/s 40(a)(ia) is attracted? IT(SS)A No.26/Ind/2023 – A.Y. 2016-17: 1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in accepting the additional evidence filed by assessee Page 6 of 83 Jarnalbeer Singh Bhatia IT(SS)A Nos. 19

THE ACIT CENTRAL-3, INDORE vs. JARNALBEER SINGH BHATIA, KHANDWA

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

section 194C(7) disallowance u/s 40(a)(ia) is attracted? IT(SS)A No.26/Ind/2023 – A.Y. 2016-17: 1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in accepting the additional evidence filed by assessee Page 6 of 83 Jarnalbeer Singh Bhatia IT(SS)A Nos. 19

PRAHLAD DAS GOYAL,BHOPAL vs. DCIT - 1(1) BHOPAL, BHOPAL

Appeal is partly allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2016-17 Prahlad Das Goyal, Dcit/Acit 1(1) 18, Shyamla Hills, Bhopal बनाम/ Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abbpg3494L Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 04.08.2025

section 194-IA came into the statute. However, the CIT(A) upheld rest of the disallowance relatable to the payments of Rs. 19

THE ACIT 3(2), INDORE vs. M/S. SIMRAN DEVELOPERS, INDORE

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2014-15 Ito-3(2), M/S. Simran Developers Indore 402, Mark Building, बनाम/ Saket Square, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Ackfs 1946 B Revenue By Shri Ashish Porwal, Sr. Dr Assessee By None Date Of Hearing 16.03.2023 Date Of Pronouncement 18.04.2023

section 40A(3). Therefore, we are of the view that the disallowance u/s 40A(3) is attracted in this case. We uphold the action of Page 14 of 16 Simran Developers Assessment year 2014-15 Ld. AO and so also the disallowance made by him. Thus, this ground is allowed. 19

COMPUTRONICS SYSTEMS (INDIA)P LTD,INDORE vs. DCIT CPC /ACIT1(1) INDORE, INDORE

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputronics Systems (India) Acit-1(1), Aayakar Bhawan Private Limited, Indore, Madhyapradesh Plant No.91, Schemeno.53, Pin 452001 Vs. Ratnalok Colony Near Rasoma Square, Indore, M.P -452001 (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaji0159C Assesseeby Shri Apurva Mehta, Ca, Ar Revenue By Shri Ashish Porwal, Acit-Sr.Dr Date Of Hearing 17.05.2023 Date Of Pronouncement 18.05.2023

19. 2. The assessee has raised following grounds of appeal: (1) On the facts and circumstances of the case and in law, the learn it CIT (Appeals)National Faceless Appeal 1 Centre, Delhi has erred in confirming the disallowance of Rs.23,64, 533/-under section