RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

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

264 is passed; Provided further that the provisions of sub-section (2) of section 274 shall apply in respect of the order imposing or enhancing or reducing penalty under this sub-section] 2. The provisions of this section as they stood immediately before their amendment by the Direct Tax Laws (Amendment) Act, 1987 (4 of 1988 ), shall apply

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 disallowance u/s 40(a)(ia) is attracted ? 5. The issues involved in various grounds raised by parties are identified and tabulated thus: No. Issue A.Y. Assessee’s Revenue’s Ground No. Ground No. 1 Unexplained investment in the form of cash loans 2013-14 1,2,3 and notional interest thereon

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 disallowance u/s 40(a)(ia) is attracted ? 5. The issues involved in various grounds raised by parties are identified and tabulated thus: No. Issue A.Y. Assessee’s Revenue’s Ground No. Ground No. 1 Unexplained investment in the form of cash loans 2013-14 1,2,3 and notional interest thereon

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of 5% by making general remarks cannot be said to be justified as has been rightly pointed out by the Ld. CIT(A) while deleting addition without any ambiguity so as to warrant interference. This ground of appeal is, therefore, found to be devoid of any merit and thus dismissed. 18. Ground No.3: Deletion of addition of Rs.5

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of 5% by making general remarks cannot be said to be justified as has been rightly pointed out by the Ld. CIT(A) while deleting addition without any ambiguity so as to warrant interference. This ground of appeal is, therefore, found to be devoid of any merit and thus dismissed. 18. Ground No.3: Deletion of addition of Rs.5

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of 5% by making general remarks cannot be said to be justified as has been rightly pointed out by the Ld. CIT(A) while deleting addition without any ambiguity so as to warrant interference. This ground of appeal is, therefore, found to be devoid of any merit and thus dismissed. 18. Ground No.3: Deletion of addition of Rs.5

ACIT CIRCLE-2(I), BHOPAL vs. MAPAAEX REMEDIES (P) LTD., BHOPAL

In the result, this appeal of revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyaniassessment Year 2014-15 Acit, Circle -2(1) Mapaaex Remedies Pvt. Ltd. Bhopal Hig-500, E-7, Arera Colony, Bhopal Vs. (Appellant / Revenue) (Respondent / Assessee) Pan No. Aaecm 2274 P Revenue By Shri Ashish Porwal, Sr. Dr Revenue By Shri Sumit Nema, Sr. Adv & Gagan Tiwari, Adv. Date Of Hearing 17.11.2022 Date Of Pronouncement 26.12.2022

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

THE ACIT-5(1), INDORE vs. M/S. SUNDERDEEP CONSTRUCTION PVT. LTD., INDORE

In the result all the grounds raised by the Revenue are

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Boradassessment Year 2012-13

Disallowance of Development expenses of Rs. 1,15,87,720 claimed in the return iv. Status of issue of ‘land purchase advances’ in the instant appeal before your Honors - Balance of land purchase advances in the name of various parties were duly disclosed in the audited balance sheet which formed part of total land purchase advances

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

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

264 ITR 276 has held as follows:- "we are of the view that having accepted at least in three assessment years that the assessee's business activity fell within the ambit of S. 80-1 of the Act, the Revenue cannot be allowed to now tum around and contend that deduction under the said section is not available to them

BANSAL PATHWAYS DAMOH KATNI P LTD,BHOPAL vs. DCIT 1(1), BHOOPAL

The appeal of the assesse is allowed for statistical purpose

Bench: Shri B.M. Biyani & Shri Paresh M Joshibansal Pathways Damoh Dcit-1(1), बनाम Katni Private Limited, Bhopal / 15Th Floor Bansal One, Vs. Rani Kamlapati Railway Station, Bhopal

Disallowance can also be made on the ground, that it will not be eligible for deduction as expenditure incurred for the purposes of business. For the aforesaid act of mine, I get reliance from the following decisions:- Page 4 of 10 Bansal Pathways Damoh Katni Pvt. Ltd ITA No.851/Ind/2024 - A.Y. 2018-19 1. Patel Filter Ltd. vs. CIT [2003] 264

ACIT (CENTRAL UJJAIN, UJJAIN vs. M/S ARIHANT FUTURE AND COMMODITIES LTD, INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 36(2)(i) is that such debt or part thereof has been taken into consideration in computing the income of the assessee of the previous year in which the amount of such debt or part thereof is written off or of an earlier previous year. I find that the appellant has duly met this requirement as well and also

THE ACIT ,CENTRAL-UJJAIN, INDORE vs. M/S ARIHANT CAPITALS MARKETS LTD , INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 36(2)(i) is that such debt or part thereof has been taken into consideration in computing the income of the assessee of the previous year in which the amount of such debt or part thereof is written off or of an earlier previous year. I find that the appellant has duly met this requirement as well and also

THE ACIT, CENTRAL - UJJAIN, INDORE vs. M/S ARIHANT FUTURE & COMMADITIES LTD , INDORE

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

section 36(2)(i) is that such debt or part thereof has been taken into consideration in computing the income of the assessee of the previous year in which the amount of such debt or part thereof is written off or of an earlier previous year. I find that the appellant has duly met this requirement as well and also