AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

b) The impugned notice lacks jurisdiction as it is hit by limitation prescribed by sub-section (2) of Section 263. It was contended by the Assessee that under Section 263(2), the impugned notice ought to have been issued within two years from the end of the financial year in which the order sought to be revised was passed

DXC TECHNOLOGY INDIA PVT LTD,INDORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), INDORE, INDORE

Appeal is allowed

b) the claim made by\nthe assessee that no expenditure has been incurred. Unless this stage is\ncrossed i.e. the stage of the AO recording that he is not satisfied with the\nclaim of assessee in the manner indicated i.e. after examining the assessee's\naccounts, the question of applying the formula under Rule 8D(2) does not\narise. This

MP STATE COOPERATIVE DAIRY FEDERATION LIMITED,BHOPAL vs. ACIT BHOPAL, BHOPAL

In the result, the appeal for A

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

disallowed the claim of Page 4 of 16 ITANo.114 & 115/Ind/2024 M.P. State Co-operative Dairy Federation Ltd. deduction u/s 80P(2)(d) of the Act in respect of the interest income received by the assessee on the fixed deposit made with Bhopal Co-operative Central Bank on the ground that the only interest or dividend received on the investment made

MP STATE CO-OPERATIVE DAIRY FEDERATION LIMITED,BHOPAL vs. ACIT, BHOPAL

In the result, the appeal for A

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

disallowed the claim of Page 4 of 16 ITANo.114 & 115/Ind/2024 M.P. State Co-operative Dairy Federation Ltd. deduction u/s 80P(2)(d) of the Act in respect of the interest income received by the assessee on the fixed deposit made with Bhopal Co-operative Central Bank on the ground that the only interest or dividend received on the investment made

SHRI HUMAD JAIN SAKH SAHAKARI SANSTHA MARYADIT,INDORE vs. ITO 2(1), INDORE

Appeal is allowed

disallowance of Rs.\n5,13,800 /- claimed u/s 80P.\"\nShri Humad Jain Sakh Sahakari Sanstha Maryadit\nITA No. 547/Ind/2024 – AY 2012-13\nGround No. 1 & 2:\n4. By means of these grounds, the assessee is raising a legal claim that\nthe AO's order is bad in law and illegal and must be annulled.\n5. With respect to these grounds

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

5. According to the Ld. AO, such excess interest to the persons covered under Section 40A(2)(b) of the Act was not available in terms of the provisions of the said Section and thus restricted the rate of interest of 12%. The balance interest of Rs.14,50,421/- was disallowed

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

5. According to the Ld. AO, such excess interest to the persons covered under Section 40A(2)(b) of the Act was not available in terms of the provisions of the said Section and thus restricted the rate of interest of 12%. The balance interest of Rs.14,50,421/- was disallowed

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

5. According to the Ld. AO, such excess interest to the persons covered under Section 40A(2)(b) of the Act was not available in terms of the provisions of the said Section and thus restricted the rate of interest of 12%. The balance interest of Rs.14,50,421/- was disallowed

INDORE SAHAKARI DUGDH SANGH MARYADIT,DAIRY COMPOUND, MANGLIA vs. COMMISSIONER OF INCOME TAX (APPEALS), NFAC, INCOME TAX DEPARTMENT, DELHI

In the result, the appeals of the assessee are allowed

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

5. We have considered rival submissions as well as relevant material on record. The AO has disallowed the claim of deduction u/s 80P(2)(d) of the Act in respect of the interest income received by the assessee on the fixed deposit made with Bhopal Co-operative Central Bank on the ground that the only interest or dividend received

INDORE SAHAKARI DUGDH SANGH MARYADIT,DAIRY COMPOUND, MANGLIA vs. COMMISSIONER OF INCOME-TAX (APPEALS), NFAC, INCOME TAX DEPARTMENT, DELHI

In the result, the appeals of the assessee are allowed

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

5. We have considered rival submissions as well as relevant material on record. The AO has disallowed the claim of deduction u/s 80P(2)(d) of the Act in respect of the interest income received by the assessee on the fixed deposit made with Bhopal Co-operative Central Bank on the ground that the only interest or dividend received

SANKALP SAKH SAHKARI SANSTHA MARYADIT,MANDSAUR vs. THE PCIT-1 , INDORE

In the result, appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisankalp Sakh Sahkari Pr. Cit-1 Sanstha Maryadit Indore 1, C/O Smriti Nagrik Sahkari Vs. Bank Dayamandir Road Goshala Market, Mandsaur (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeas0312G Assessee By Shri Anil Kamal Garg, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 25.01.2024 Date Of Pronouncement 30.01.2024

b)….. c)………. (d) In respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income. Section 80P(2)(d) envisages deduction for interest income earned only from co- operative societies and not from co- operative banks. However, you have earned interest

M/S VIJAY PULSES,INDORE vs. THE ACIT 4(1), INDORE

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani(Conducted Through Virtual Court) M/S. Vijay Pulses, Dcit, Cpc, 12, Sajan Nagar, Bangalore Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaafv 9714 E Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 30.01.2023 Date Of Pronouncement 13.03.2023

b) of the audit report, then, in our considered view, the requirement of section 143(1) of the Act viz. “disallowance of expenditure ….indicated in the tax audit report” stands satisfied and the Department is permitted to make disallowance in terms of section 143(1) of the Act. 6.3 With regards to the second argument of the counsel

JYOTI GOYAL,BHOPAL vs. DCIT-1(1), BHOPAL

Appeal is partly allowed as mentioned above

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2012-13 Jyoti Goyal, Dcit, 18, Shyamla Hills, 1(1), बनाम/ Bhopal Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abbpg3493P Assessee By Shri S.S. Deshpande, Ca & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 25.04.2024 Date Of Pronouncement 20.05.2024

section 69 treating the same as unexplained deposit. (4) That on the facts and in the circumstances of the case of the assessee the ld. CIT(A), Delhi, was not justified in confirming disallowance of addition of Rs. 15,50,000/- towards cash received by assessee treating the same on unexplained cash.” 2. The background facts leading to present appeal

ASST. COMMISSIONER OF INCOME TAX (CENTRAL)-I, BHOPAL , BHOPAL vs. SOM DISTILLERIES PRIVATE LIMITED, BHOPAL

Appeal is partly allowed for statistical

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

b) of revenue are devoid of any merit, accordingly they are rejected. Ground No. 2: 12. In this ground, the revenue challenges the CIT(A)’s action of deleting the disallowance of Rs. 6,00,00,000/- made by AO out of purchase expenditure claimed by assessee. 13. The AO has made this disallowance vide Para 5 of assessment-order

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

b) of revenue are devoid of any merit, accordingly they are rejected. Ground No. 2: 12. In this ground, the revenue challenges the CIT(A)’s action of deleting the disallowance of Rs. 6,00,00,000/- made by AO out of purchase expenditure claimed by assessee. 13. The AO has made this disallowance vide Para 5 of assessment-order

CMM KETI JV,INDORE vs. ITO 1(3), INDORE, INDORE

Appeal is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Cmm Keti Jv, Income-Tax Officer, 108, Shalimar Corporate 1(3), Center, Indore. बनाम/ 8-B, South Tukoganj, Vs. Indore. (Assessee/Appellant) (Revenue/Respondent) Pan: Aakfc7524K Assessee By Shri Shashank Sharma, Ca & Shri Prakash Gupta, Ca Revenue By Shri Sanjeev H. Bhagat, Sr. Dr Date Of Hearing 11.12.2024 Date Of Pronouncement 20.01.2025

section 40A(2)(b) of the Act. 8.5 In view of the above facts of the appellant's case and the judicial pronouncement of the Jurisdictional High Court I come to a conclusion that the amount paid by the appellant to M/s. CRM Infra Projects Ltd, was definitely higher than the actual market value. The said payment was not certainly

MILLION TRADERS BHOPAL P LTD,BHOPAL vs. THE ACIT,CPC,BENGALURU, BENGALURU

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

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

disallowance is made by the CPC while processing the return u/s 143(1) therefore, the assessee had no occasion to produce the supporting evidence to show that the TCS was collected by the Excise Department in respect of the purchase made and accounted by the assessee. Page 4 of 24 ITA No.124/Ind/2023 & ITANo.35/Ind/2023 Million Trader Bhopal Page 5

MILLION TRADERS BHOPAL P LTD,BHOPAL vs. THE ACIT,CPC,BENGALURU, BENGALURU

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

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

disallowance is made by the CPC while processing the return u/s 143(1) therefore, the assessee had no occasion to produce the supporting evidence to show that the TCS was collected by the Excise Department in respect of the purchase made and accounted by the assessee. Page 4 of 24 ITA No.124/Ind/2023 & ITANo.35/Ind/2023 Million Trader Bhopal Page 5