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 65A and 65B of the Indian Evidence Act 1872 providing for admissibility of electronic records as evidence have not been followed. The appellant has also placed reliance on certain decisions wherein on identical facts, similar addition made have been deleted. The appellant has also challenged the addition made on protective basis on the contention that the said amount

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

48,60,628/- made under Section 14A of the Income Tax Act, 1961 (’the Act’) and 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

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

48,60,628/- made under Section 14A of the Income Tax Act, 1961 (’the Act’) and 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

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

48,60,628/- made under Section 14A of the Income Tax Act, 1961 (’the Act’) and 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

HONOURABLE PACKAGING P LTD ,DHAR vs. THE DCIT 1(1), INDORE

In the result, the appeal of the assessee is dismissed

Bench: The Due Date Of Filing Of The Income Tax Return & Can It Be Disallowed In The 143(1).

48,560/-. The assessee received communication from Computer Processing Centre, Bengaluru u/s. 143(1)(a)(iv) that the disallowances of expenditure indicated in the audit report but not taken into account in computing the total income in the return of Rs. 2,13,334/-. 2.2. The assessee replied that they have duly clubbed disallowances in filing of Income Tax Return

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of the amount deducted by PWD is not sustainable and, thus, deleted. We thus set aside the findings of Ld. CIT(A) on this count. Hence, assessee’s cross objection is allowed. Accordingly, the appeal filed by the Revenue is dismissed whereas cross objection filed by the assessee is allowed. ITA No.217/Ind/2021 A.Y. 2011-12 16 Surya Infraventure

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of the amount deducted by PWD is not sustainable and, thus, deleted. We thus set aside the findings of Ld. CIT(A) on this count. Hence, assessee’s cross objection is allowed. Accordingly, the appeal filed by the Revenue is dismissed whereas cross objection filed by the assessee is allowed. ITA No.217/Ind/2021 A.Y. 2011-12 16 Surya Infraventure

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowance of the amount deducted by PWD is not sustainable and, thus, deleted. We thus set aside the findings of Ld. CIT(A) on this count. Hence, assessee’s cross objection is allowed. Accordingly, the appeal filed by the Revenue is dismissed whereas cross objection filed by the assessee is allowed. ITA No.217/Ind/2021 A.Y. 2011-12 16 Surya Infraventure

M/S RAJIV GANDHI PROUDYOGIK VISHWAVIDHALYA,HOSANGABAD vs. DCIT CPC, BENGALURU

In the result, the appeal of the assessee in I

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 324 & 325/Ind/2018 "नधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Rajiv Gandhi Proudyogiki Vs. Dcit, Vishwavidyalaya, Cpc, Bhopal Bangaluru

disallowance of deduction claimed under sections 10AA, 80IA,, 80-IAB, 80IB, 80-IC, 80-ID or section 80IE, if the return is furnished beyond the due date specified under sub-section (1) of section 139; ,or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income

M/S RAJIV GANDHI PROUDYOGIK VISHWAVIDHALYA,HOSANGABAD vs. DCIT CPC, BENGALURU

In the result, the appeal of the assessee in I

Bench: Shri Kul Bharat & Shri Manish Boradआ.अ.सं /.I.T.A. No. 324 & 325/Ind/2018 "नधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Rajiv Gandhi Proudyogiki Vs. Dcit, Vishwavidyalaya, Cpc, Bhopal Bangaluru

disallowance of deduction claimed under sections 10AA, 80IA,, 80-IAB, 80IB, 80-IC, 80-ID or section 80IE, if the return is furnished beyond the due date specified under sub-section (1) of section 139; ,or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income

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

disallowed u/s 40A(3) of the Act. The Hon'ble High Court held that rule 6DD(j) is not exhaustive of the circumstances in which the proviso to section 40A(3) is applicable and it only illustrative. The Hon'ble High Court refers to the decision of the Hon'ble Rajasthan High Court in case of Smt. Harshila Chordia

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

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

JILA SAHAKARI KENDRIYA BANK MYDT,SEHORE, MP vs. COMMISIONER OF INCOME TAX (APPEALS), NFAC, DELHI

Appeal is partly allowed for statistical purposes

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Jila Sahakari Kendriya Cit(A), Nfac, Delhi / Bank Mydt, Acit-3(1), Bhopal बनाम/ Sehore, M.P. Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaalj0022F Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 10.04.2026

section 2(24)(x) r.w.s. 36(1)(va). 14. Presently, the assessee is making a limited claim that the amount of Rs. 50,500/- is not fully on account of employee’s contribution, it also has Page 16 of 18 Jila Sahakari Kendriya Bank Mydt, Sehore ITA No. 407/Ind/2024 – AY 2014-15 component of employer’s contribution which

KOMAL KUMAR JAIN,INDORE vs. DCIT,CPC BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

disallowance of Rs. 5,48,663 under Section 36(1)(va) of the Act for delayed payment of employees’ contribution

ACIT CENTRAL-2 INDORE, INDORE vs. SHRI .GAURAV TEKRIWAL, INDORE

In the result, this appeal of Revenue is dismissed

Bench: Ms. Madhumita Roy & Shri B.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Acit, Central -2 Shri Gaurav Tekriwal Indore बनाम/ 204, Princess Valley, South Tukoganj, Indore Vs. (Appellant / Revenue) (Respondent / Revenue) Pan: Acppt 1628 Q Assessee By Shri Anil Kamal Garg, Arpit Gaur, Ars Revenue By Shri P.K. Mitra, Cit-Dr Date Of Hearing 21.09.2022 Date Of Pronouncement 21.11.2022

48,892/- on the footing that the assessee has not filed any submission on merit. Ld. AO has also quoted section 57(iii) which provides that the deduction of expenditure is allowed only if an expenditure is incurred for the purpose of making or earning income. Thus, in essence, Ld. AO has disallowed

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

48,77,146/- on account of disallowance of deduction claimed by the assessee under section 80IC of the Income-tax Act, 1961.” Mapaaex

THE DCIT, 2(1), INDORE vs. M/S. TREASURE WORLD DEVELOPERS PVT. LTD., INDORE

In the result both the Cross Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S. Treasure World Acit 4(1), बनाम/ Developers Pvt. Ltd, Indore Vs. Through Office Of The Official Liquidator, High Court Of Bombay, Bank Of India Building, 5Th Floor, M.G. Road, Indore (Pan: Abopb0352F ) (Assessee/Appellant) (Revenue/Respondent) Acit 4(1), M/S. Treasure World बनाम/ Indore Developers Pvt. Ltd, Vs. Through Office Of The Official Liquidator, High Court Of Bombay, Bank Of India Building, 5Th Floor, M.G. Road, Indore (Pan: Abopb0352F ) (Revenue/Appellant) (Assessee/Respondent)

section 14A(1) is enacted to ensure that only expenses incurred in respect of earning taxable income are allowed. 13. The aforesaid discussion now leads us to only one conclusion that since appellant has made substantial investment of Rs. 135.46 Crores in shares of subsidiary and other companies mainly from borrowed funds, therefore, a disallowance of such interest expenses