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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

55,000/- as made by Ld assessing officer to the total income of the respondent assessee company on account of disallowance of amount paid to PWD under section

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

55,000/- as made by Ld assessing officer to the total income of the respondent assessee company on account of disallowance of amount paid to PWD under section

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

55,000/- as made by Ld assessing officer to the total income of the respondent assessee company on account of disallowance of amount paid to PWD under section

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

disallowed by 53 M/s.Rajiv Gandhi Proudyogiki Vishwavidyalaya,Bhopal. way of an intimation under section 143(1)(a) of the Act. 14. We are conscious of the fact that Section 36(1)(vii) of the Act was amended by the Finance act, 2001 by insertion of Explanation to Section 36(1)(vii) of the Act w.e.f. Ist April

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

disallowed by 53 M/s.Rajiv Gandhi Proudyogiki Vishwavidyalaya,Bhopal. way of an intimation under section 143(1)(a) of the Act. 14. We are conscious of the fact that Section 36(1)(vii) of the Act was amended by the Finance act, 2001 by insertion of Explanation to Section 36(1)(vii) of the Act w.e.f. Ist April

M/S. S.R. FERRO ALLOYS,JHABUA vs. THE PCIT, BHOPAL

In the result, the appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanis.R. Ferro Alloys Pr. Cit, Central 9, Siddheswar Colony Bhopal Vs. Jhabua (Appellant / Assessee) (Revenue) Pan: Abhfs7377Q Appellant By Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2023 Date Of Pronouncement 09.11.2023

55 disallowance of interest and questioning the unsecured loans shown by the assessee however, the issue of disallowance of interest was dropped by the Pr. CIT and the impugned order was passed only on the issue of failure on the part of the AO to examine and verified the identity and genuineness of the unsecured loans. Since this issue

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

disallowance of employee’s contribution to PFand ESI is not justified and liable to be deleted. 5. On the other hand, the learned DR has submitted that the issue is now settled and covered by the decision of Hon’ble Supreme Court in the case of Checkmate Services Pvt. Ltd. Vs. Commissioner of Income

ACIT, KHANDWA vs. M/S C.P. INDUSTRIAL PRODUCTS PVT. LTD. , BURHANPUR

In the result the appeal of the revenue is dismissed

Bench: Hon'Ble V. Durga Rao & Hon'Ble Manish Boradassessment Year 2010-11 Assistant Commissioner Of M/S. C.P. Industrial Income Tax, Vs. Products Pvt. Ltd, Khandwa Burhanpur (M.P) (Appellant) (Respondent ) Pan No.Aaccc1362 Revenue By Shri K.G. Goyal. Sr. D.R. Assessee By S/Shri S.N. Agrawal & Pankaj Mogra, Ca’S Date Of Hearing 25.02.2019 Date Of Pronouncement 27.02.2019 O R D E R

disallowance under section 14A cannot exceed the dividend amount received by it. For this preposition, reliance was placed on the following direct decisions:- S.No Name of Decision Citation CIT V/s Lakhani 01. 49 taxmann.com 257 (P&H) Marketing CIT V/s Cortech Energy P. 02. 45 taxmann.com 116 (Guj) Ltd. CIT V/s Shivam Motors P. 03. 55

THE DCIT1(1), INDORE vs. SHRI RAVI ARORA, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2011-12 Dcit-5(1), Shri Ravi Arora, Indore 1007, Khatiwala Tank, बनाम/ 236, Indraprasth Tower, 6, M.G. Road, Vs. Indore. (Revenue / Appellant) (Assessee / Respondent) Pan: Agdpa8921H Assessee By Shri Yash Kukreja, Ca & Shri Hitesh Chimnani, Adv & Ld. Ars Revenue By Shri P.K.Mishra, Cit Dr Date Of Hearing 04.05.2023 Date Of Pronouncement 31.07.2023

section 40A(3) of the I. T. Act.” 2. Heard the learned Representatives of both sides at length and case- records perused. 3. Brief facts leading to present appeal are such that the assessee- individual submitted his return of income declaring a total income of Rs. 17,29,650/- which was subjected to scrutiny assessment u/s 143(2). Finally

DCIT CENTRAL-2 , INDORE vs. M/S. KETI-KJ CONSTRUCTION (INDIA) LTD., , INDORE

In the result the appeal of the revenue stands dismissed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2013-14 Dcit-(Central)-2, V/S M/S. Keti-Kj Construction Indore (India) Ltd, 31/6, Vatsalya Chambers, Sneh Nagar, Indore

disallowance u/s 14A of the Act at Rs.1,55,20,966/-. There is no dispute to the fact that ‘no exempt income’ has been earned by the assessee during the year. Hon'ble High Court of Delhi in the case of Cheminvest v/s CIT (2015) 61 taxmann.com 118 (Del) (supra) has laid down the ratio that Section

THE ACIT-2(1), UJJAIN vs. SHRI JASWINDAR SINGH OBEROI, UJJAIN

In the result, appeal of revenue is partly allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

disallowance under section 40A(3) shall not applicable. In the light of above , the Ld. CIT (A) held that the payment is made by the Appellant to Government Authorized agents is falling under exceptions provided under rule 6DD. The Ld. CIT (A) further observed that the ledger account of payment has been produced during the course of appellate proceedings

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

55 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for A.Y. 2001-01 to 2003-04 dtd. 28.12.2011 was passed relying orders of earlier years, hence, the Tribunal has not considered the scope of retrospective effect

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

55 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for A.Y. 2001-01 to 2003-04 dtd. 28.12.2011 was passed relying orders of earlier years, hence, the Tribunal has not considered the scope of retrospective effect

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

55 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for A.Y. 2001-01 to 2003-04 dtd. 28.12.2011 was passed relying orders of earlier years, hence, the Tribunal has not considered the scope of retrospective effect

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

55 of 84 M/s. Andritz Hydro Pvt. Ltd v DCIT/ T.P.A. No.157/Ind/2015 &316/Ind/2016/ A.Y.:10-11&11-12 DCIT vs. Andritz Hydro Pvt. Ltd T.P. A. No. 265/Ind/2015 & 349/Ind/2016/A.Y.:10-11&11-12 for A.Y. 2001-01 to 2003-04 dtd. 28.12.2011 was passed relying orders of earlier years, hence, the Tribunal has not considered the scope of retrospective effect

THE ACIT, 1(1), BHOPAL vs. M/S. SANWARIA AGRO OILS LIMITED, BHOPAL

In the result, the appeal of the revenue is partly allowed for

Bench: Shri C.M. Garg & Shri O.P. Meena

55,839/- being ½% of the investment made during the year. However, rule 8D provides for a disallowance at ½% of the average investment during the year besides a disallowance of interest computed in the manner provided in rule 8D. The Assessing Officer made the disallowance accordingly. 4. Being aggrieved with the disallowance made by the Assessing Officer, the assessee approached

CHARCHIT GARG,INDORE vs. INCOME TAX OFFICER, INDORE

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

55,741/- was duly discharged through TDS, advance tax and self- assessment tax. 4. The return of income was processed by the CPC under section 143(1) of the Act on 31.07.2024. While processing the return, the Assessing Officer disallowed