M/S RADHISHWARI DEVLOPERS P LTD,INDORE vs. PR CIT -2 INDORE, INDORE

In the result, Assessee’s appeal in ITANo

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing Assessment Year 2013-14 M/S. Radhishwari Developers P. Ltd. (Now Known As R.C. Warehousing Pvt. Ltd. ) Indore : Appellant Pan :Aafcr1916A V/S Pr. Cito-2 : Respondent Indore Appellant By S/Shri Sumit Nema Sr. Adv. With Gagan Tiwari & Piyush Parashar Advs. Revenue By Shri S.S. Mantri, Cit-Dr Date Of Hearing 24.05.2021 Date Of Pronouncement 20.07.2021

disallowing said payments under section 40A (3)- Whether on facts, impugned revisional order did not require any interference- Held, yes [Para-16] [ In favour of revenue] 4.0 Therefore, in view of the above discussion I am of the considered opinion that the order dated: 06.01.2016 for A.Y. 2013-14 is erroneous in so far as it is also prejudicial

ROSHAN HOSPITAL,BHOPAL vs. DCIT-5(1), BHOPAL

In the result, the appeal of the assessee is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 Roshan Hospital, Dcit/Acit, 7-A-B, Govind Garden, 5(1), Bhopal बनाम/ Raisen Road, Govindpura, Vs. Bhopal-462023 (Appellant /Assessee) (Respondent / Revenue) Pan: Aasfr 4278 B Assessee By Ms. Shreya Jain, Ar Revenue By Shri. Ashish Porwal, Sr. Dr Date Of Hearing 01.03.2023 Date Of Pronouncement 06.04.2023

67,81,672/-. During the scrutiny assessment, the AO made the addition on account of belated payment to ESI and EPF towards employees contribution under section 36(1)(va) r.w.s. 2(24)(x) of the Income Tax Act of Rs. 3,92,101/-. The assessee challenged the action of the AO before the CIT(A) but could not succeed

RNG CONSTRUCTION CO,INDRA NAGAR vs. DCIT-CPC, CPC-BENGALURU

Appeal is allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshirng Construction Co. Dcit-Cpc 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

section 143(1), being debatable. 3. That, on the facts and circumstances of the case and in law and without prejudice to above, the Ld. CIT(A) erred in confirming disallowance u/s 43B in respect of Service Tax amounting to Rs. 44,77,216/- and Professional Tax amounting to Rs. 67

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

section 32(1) by making a sufficient note in assessment-order. Consequently, we uphold AO’s action. The assessee fails in this ground. Ground No. 23: 32. This ground relates to the cost of Rs. 73,10,920/- incurred by assessee towards licensed software treated by AO as capital expenditure. 33. The assessee has incurred cost towards purchase of licensed

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 68 of the Act pertaining to accommodation entry received by the assessee through shell entities and has also paid commission to the intermediaries @ 1%. The ld. CIT-DR submitted that the AO made addition by considering the statement of Director of Mega Money Commodities Pvt. Ltd. (MMCPL) which was deleted by the ld.CIT(A) without any basis. Therefore

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 68 of the Act pertaining to accommodation entry received by the assessee through shell entities and has also paid commission to the intermediaries @ 1%. The ld. CIT-DR submitted that the AO made addition by considering the statement of Director of Mega Money Commodities Pvt. Ltd. (MMCPL) which was deleted by the ld.CIT(A) without any basis. Therefore

THE ADDL. CIT RANGE -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 68 of the Act pertaining to accommodation entry received by the assessee through shell entities and has also paid commission to the intermediaries @ 1%. The ld. CIT-DR submitted that the AO made addition by considering the statement of Director of Mega Money Commodities Pvt. Ltd. (MMCPL) which was deleted by the ld.CIT(A) without any basis. Therefore

ASHA RANI PANDYA,INDORE vs. CPC BANGALORE, BANGALORE

In the result, the appeal is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniasha Rani Pandya Dcit/Acit-1(1) 389 1Ad- Scheme No.74C Indore Vijay Nagar, Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aqqpp7081A Assessee By Ms. Shreya Jain & Shri Prakash Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.06.2024 Date Of Pronouncement 28 .06.2024

section 90 of Income Tax Act. However, the CPC while processing return of income u/s 143(1) has denied the claim of credit of tax paid on the income earned in USA due to delay in filing the form 67. On appeal the CIT(A) has confirmed the 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

1) of the Act , has been duly complied with, by the assessee and subsequently assessment completed u/s 143(3) of the Act accepting the returned income, without any variation and without much discussion in the assessment order. 5. The three basic issues for which the case was selected for scrutiny where as follows: “i. Claim of Any Other Amount Allowable

THE ACIT-1(1), INDORE vs. M/S. BRIDGESTONE INDIA PVT. LTD., PUNE

In the result, the appeal of revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniacit-1(1) M/S. Bridgestone India Pvt. Ltd. Indore Plot No.A-43, Phase-Ii, Midc, Vs. Chakan, Pune, Maharastra (Appellant / Revenue) (Assessee) Pan: Aabcb2304E Revenue By Shri Ankit Guttani & Yash Daga, Ars Assessee By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.09.2023 Date Of Pronouncement 22.09.2023

1)(va) are satisfied i.e., depositing such amount received or deducted from the employee on or before the due date. In other words, there is a marked distinction between the nature and character of the two amounts – the employer’s liability is to be paid out of its income whereas the second is deemed an income, by definition, since

ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION) CIRCLE BHOPAL, BHOPAL vs. MAYANK WELFARE SOCIETY, INDORE

In the result, Revenue’s appeal for the AY 2013-14

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing Assessment Year: 2013-14

67,098/- and capital expenditure at Rs.21,22,84,057/-. Ld. Assessing Officer also observed that in the balance sheet under the head corpus funds a sum of Rs.14,06,75,754/- was shown to be received as donation during the year towards corpus funds. Mayank Welfare society ITANos.232 & 776/Ind/2018/17 6. Ld. Assessing Officer asked the assessee to file

THE DCIT, (EXEMPTION) CIRCLE, BHOPAL vs. M/S. MAYANK WELFARE SOCIETY, BHOPAL

In the result, Revenue’s appeal for the AY 2013-14

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing Assessment Year: 2013-14

67,098/- and capital expenditure at Rs.21,22,84,057/-. Ld. Assessing Officer also observed that in the balance sheet under the head corpus funds a sum of Rs.14,06,75,754/- was shown to be received as donation during the year towards corpus funds. Mayank Welfare society ITANos.232 & 776/Ind/2018/17 6. Ld. Assessing Officer asked the assessee to file

M/S. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

disallowance under Section 14A of the Act can be made if the assessee had not earned any exempt income), as the revenue has not been accepted the said decision and has preferred an SLP against the said decision. 4. Learned counsel for the petitioner also submits that in view of the amendment made by the Finance Act, 2022 to Section

SHRI BHAWANI SHANKAR PARASHAR,INDORE vs. THE DCIT/ACIT 1 (2), INDORE

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Bhawani Shankar Pr. Cit-1 Prashar Indore 28, Lasudia Mori, Vijay Vs. Nagar, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Bgbpp 2475 G Assessee By Shri S.N. Agrawal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 21.06.2023

disallowed by the Assessing Officer. On the ground of merger, the Court held that the Commissioner could not have exercised the revisional powers. 11. The Gujarat High Court in case of Haryana Paper Distributors P Ltd (supra) was concerned with a notice issued by the Commissioner for exercising revisional powers under Section 263 of the Act. It was a case

DCIT (CENTRAL), BHOPAL vs. SHAILENDRA SHARMA, BHOPAL

In the result the appeals of the assessee for the Assessment

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

section 158BC in the case of 'R' did not survive at all since it had been struck down being time barred. The additions made on substantive basis had not been decided by deleting the same from assessee's individual hands rather they were thrown along with the block assessment order, meaning thereby, there was no substantive addition in existence

AISECT LTD. ,BHOPAL vs. ACIT RANGE 1(1), BHOPAL

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Roy

67,06,000 Total 8,14,42,700 Details of the expenses are explained herein below: i. AISECT Bhopal: The said entity is managing a University in the name of AISECT, Bhopal having a very large infrastructure and the courses conducted for all the subjects. It may be mentioned that the assessee has received Rs. 8,97,87,640/- from

AISECT LTD. ,BHOPAL vs. ACIT RANGE 1(1), BHOPAL

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Roy

67,06,000 Total 8,14,42,700 Details of the expenses are explained herein below: i. AISECT Bhopal: The said entity is managing a University in the name of AISECT, Bhopal having a very large infrastructure and the courses conducted for all the subjects. It may be mentioned that the assessee has received Rs. 8,97,87,640/- from

ACIT RANGE 1(1), BHOPAL vs. AISECT LTD. , BHOPAL

Bench: Hon’Ble Manish Borad & Hon’Ble Madhumita Roy

67,06,000 Total 8,14,42,700 Details of the expenses are explained herein below: i. AISECT Bhopal: The said entity is managing a University in the name of AISECT, Bhopal having a very large infrastructure and the courses conducted for all the subjects. It may be mentioned that the assessee has received Rs. 8,97,87,640/- from