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

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

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

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

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

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowing entire deprecation claimed by appellant and secondly not justified in estimating NP @ 5%. Thus, addition made by the AO amounting to Rs. 2,04,60,184/- is Deleted. Therefore, appeal on this ground is Allowed.” 18. We have considered rival contentions and gone through the material available on record. We find that the facts discussed above squarely establish that

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowing entire deprecation claimed by appellant and secondly not justified in estimating NP @ 5%. Thus, addition made by the AO amounting to Rs. 2,04,60,184/- is Deleted. Therefore, appeal on this ground is Allowed.” 18. We have considered rival contentions and gone through the material available on record. We find that the facts discussed above squarely establish that

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

Bench: Ms. Madhumita Roy & Shri Bhagirath Mal Biyani

disallowing entire deprecation claimed by appellant and secondly not justified in estimating NP @ 5%. Thus, addition made by the AO amounting to Rs. 2,04,60,184/- is Deleted. Therefore, appeal on this ground is Allowed.” 18. We have considered rival contentions and gone through the material available on record. We find that the facts discussed above squarely establish that

THE ACIT, 2(1), BHOPAL vs. M/S MOENUS TEXTILE PVT. LTD., BHOPAL

In the result, appeal of the revenue in ITANo

Bench: Shri Mahavir Prasad & Shri Manish Boradvirtual Hearing Assessment Year: 2009-10

70,099/- u/s 40(a)(ia) of the Act. Accordingly, sround no.2 raised by the revenue stands dismiss. 9. Apropos to ground no.3 relating to disallowance of legal and professional expenses of Rs.16,08,000/- which have been deleted by the ld. CIT(A) and revenue has challenged this finding, we note that brief facts relating to this issue

NAMTEL TECHNOLOGIES P LTD ,BHOPAL vs. ACIT(A) NFAC NEW DELHI, DELHI

In the result, this appeal of Assessee is partly allowed

Bench: Ms.Suchitra Kamble & Shrib.M. Biyani(Conducted Through Virtual Court) Assessment Year: 2015-16 Namtel Technologies (P) Dcit-3(1), Ltd., Bhopal बनाम/ Bhopal Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aaccn6502F Assessee By Shri S.S.Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.08.2022 Date Of Pronouncement 16.11.2022

section 40A(2). Ld. DR, therefore, prayed to uphold the disallowance. 11. We have considered rival submissions of both sides and perused the material held on record. We observe that the assessee has paid impugned remuneration to a director, who is holding a qualification of Mechanical Engineer from reputed Jamia Milia Islamia, New Delhi and also possessing experience in computer

THE ACIT-2(1), UJJAIN vs. M/S. TURQUISE INVESTMENT & FINANCE PVT.LTD., NAGDA

In the result, against total disallowance of Rs

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Borad

section 14A of the Act reference is given to the method provided in Rule 8D of the IT Rules which has following three limbs: (i) the amount of expenditure directly relating to income which does not form part of total income; (ii) Computing of disallowance of interest expenditure incurred during the year which is not directly attributable to any particular

PRAHLAD DAS GOYAL,BHOPAL vs. DCIT - 1(1) BHOPAL, BHOPAL

Appeal is partly allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2016-17 Prahlad Das Goyal, Dcit/Acit 1(1) 18, Shyamla Hills, Bhopal बनाम/ Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abbpg3494L Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 04.08.2025

section 194-IA came into the statute. However, the CIT(A) upheld rest of the disallowance relatable to the payments of Rs. 19,00,000/- [the amount of disallowance upheld by CIT(A) comes to Rs. 5,70

ASSISTANT COMMISSIONER OF INCOME TAX- 2(1), INDORE vs. M/S. IDEAL ASHIYANA PRIVATE LIMITED, INDORE

Bench: Ms. Madhumita Roy & Shri B.M. Biyaniassessment Year: 2013-14 Acit-2(1) M/S Ideal Ashiyana Indore Private Ltd., Indore बनाम/ Vs. (Appellant / Revenue) (Respondent / Assessee) Pan: Aadci 0029 F Assessee By Shri Pankaj Shah, Ar Revenue By Shri P.K. Mitra, Cit-Dr Date Of Final Hearing 27.09.2022 Date Of Pronouncement 15.12.2022

70,15,725/- is Deleted. Therefore, the appeal on this ground is Allowed.” 10. Before us, Ld. DR supported the assessment-order. Per contra, Ld. AR relied upon the order of Ld. CIT(A). 11. We have considered rival submissions of both sides. We observe that the assessee is a company, engaged in the business of land and building. During

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

70,000 13,34,319 Computer Services Ltd Total 44,81,373 8.1 The Appellant had submitted confirmation as evidence in respect of off- market purchase through broker M/s. Eden Financial Services, copies of sale invoices executed online through stock exchange after payment of Securities transaction tax, copies of ledger and other supporting documents and claimed that the disallowance

THE ACIT, CENTRAL-1, INDORE vs. M/S. ARIHANT CAPITAL MARKETS LTD., INDORE

In the result, the appeal of the revenue and cross objection of

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2013-14

section 14A r.w.r. 8D cannot be made applicable in a vacuum i.e. in the absence of exempt income. Decision of Honorable Gujarat High Court in CIT Vs. Corrtech Energy (P.) Ltd. [(2015) 372 ITR 0097 (Guj) E For the proposition that the disallowance is not tenable where the AO did not recorded proper satisfaction. Decision of Honorable High Court

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

70,36,460/- which was assessed at Rs. 2,67,53,240/- by making disallowances and addition. The assessee has made payments of Rs. 1, 39,60,280/- to various country liquor warehouses which are authorized agents of the government for delivering country liquor. Out of this , an amount of Rs. 1,26,13.496/- was disallowed under section

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

section 9(1)(vi) and section 9(1)(vii)of the Act as well as under India- Austria Tax Treaty on which TDS was not made hence, the AO has rightly disallowed the same under section 40(a)(ia) of the Act. 6.5. We have heard the rival submissions of both the parties and have perused the material available

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

section 9(1)(vi) and section 9(1)(vii)of the Act as well as under India- Austria Tax Treaty on which TDS was not made hence, the AO has rightly disallowed the same under section 40(a)(ia) of the Act. 6.5. We have heard the rival submissions of both the parties and have perused the material available

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

section 9(1)(vi) and section 9(1)(vii)of the Act as well as under India- Austria Tax Treaty on which TDS was not made hence, the AO has rightly disallowed the same under section 40(a)(ia) of the Act. 6.5. We have heard the rival submissions of both the parties and have perused the material available