SHREENATHJI INFRASTRUCTURE P.LTD.,PIPARIYA vs. ASSISTANT COMMISSIONER OF INCOME TAX , ITARSI

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

disallowance u/s 80IA. During the year, the appellant has constructed roads at various places in M.P. under contracts received from Executive Engineer, PWD, Mandaleshwar, Shajapur, Raisen, and Chhindwara, M.P.R.R.D.A., Maheshwar, and MPRRDA, Sehore. A perusal of relevant bidding documents, letter of acceptance, notice inviting tender, notice to proceed the work etc. shows as follows:- (i) Detailed notice inviting tender

SHREENATHJI INFRASTRUCTURE P.LTD.,PIPARIYA vs. ASSISTANT COMMISSIONER OF INCOME TAX , ITARSI

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

disallowance u/s 80IA. During the year, the appellant has constructed roads at various places in M.P. under contracts received from Executive Engineer, PWD, Mandaleshwar, Shajapur, Raisen, and Chhindwara, M.P.R.R.D.A., Maheshwar, and MPRRDA, Sehore. A perusal of relevant bidding documents, letter of acceptance, notice inviting tender, notice to proceed the work etc. shows as follows:- (i) Detailed notice inviting tender

SHREENATHJI INFRASTRUCTURE P.LTD.,PIPARIYA vs. ASSISTANT COMMISSIONER OF INCOME TAX , ITARSI

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

disallowance u/s 80IA. During the year, the appellant has constructed roads at various places in M.P. under contracts received from Executive Engineer, PWD, Mandaleshwar, Shajapur, Raisen, and Chhindwara, M.P.R.R.D.A., Maheshwar, and MPRRDA, Sehore. A perusal of relevant bidding documents, letter of acceptance, notice inviting tender, notice to proceed the work etc. shows as follows:- (i) Detailed notice inviting tender

SHREENATHJI INFRASTRUCTURE P.LTD.,PIPARIYA vs. ASSISTANT COMMISSIONER OF INCOME TAX , ITARSI

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

disallowance u/s 80IA. During the year, the appellant has constructed roads at various places in M.P. under contracts received from Executive Engineer, PWD, Mandaleshwar, Shajapur, Raisen, and Chhindwara, M.P.R.R.D.A., Maheshwar, and MPRRDA, Sehore. A perusal of relevant bidding documents, letter of acceptance, notice inviting tender, notice to proceed the work etc. shows as follows:- (i) Detailed notice inviting tender

SHREENATHJI INFRASTRUCTURE P.LTD.,PIPARIYA vs. DEPUTY COMMISSIONER OF INCOME TAX , ITARSI

Bench: Shri Chandra Mohan Garg & Shri B.M. Biyani

disallowance u/s 80IA. During the year, the appellant has constructed roads at various places in M.P. under contracts received from Executive Engineer, PWD, Mandaleshwar, Shajapur, Raisen, and Chhindwara, M.P.R.R.D.A., Maheshwar, and MPRRDA, Sehore. A perusal of relevant bidding documents, letter of acceptance, notice inviting tender, notice to proceed the work etc. shows as follows:- (i) Detailed notice inviting tender

DCIT 3 (1) , BHOPAL vs. M/S NHDC LTD, BHOPAL

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

disallowance has been confirmed despite the fact that the said incomes are directly derived from the eligible business of the assessee and deduction is allowable under section 801A

NHDC LIMITED,BHOPAL vs. DCIT - 3(1), BHOPAL, BHOPAL

In the result, the appeal of the revenue is dismissed, Cross appeal of the assesse is partly allowed for statistical purposes and CO is dismissed being infructuous

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninhdc Limited Dcit, 3(1) F-01, Nhdc Parisar, Shyamla Bhopal Vs. Hills Bhopal -462013 (Appellant / Assessee) (Revenue) Pan: Aabcn 1732G Dcit, 3(1) Nhdc Limited Bhopal F-01, Nhdc Parisar, Vs. Shyamla Hills Bhopal -462013 (Appellant / Revenue) (Assessee) Pan: Aabcn 1732G

disallowance has been confirmed despite the fact that the said incomes are directly derived from the eligible business of the assessee and deduction is allowable under section 801A

DCIT-4(1), INDORE, INDORE vs. ODDIVILLE FOODS AND FROZEN, INDORE

Accordingly, the grounds raised by the Revenue are dismissed\nand the order of the Ld

section 801A read with rule 18BBB. the assessee was\nrequired to upload Form 10CCB by the due date of filing of\nreturn of income. The assessee has admittedly failed in\ndoing so.\nIn light of the fact that the provision of law is\nunambiguous and does not allow for a liberal\ninterpretation the deduction claimed u/s 35AD

THE ACIT CENTRAL-1, BHOPAL vs. M/S RAMDEV SUGARS P LTD, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Acit Central-1 M/S. Ramdev Sugars Pvt. Indore Ltd. बनाम/ 25, Nasia Road, Near Bus Stand, Vs. Indore (Appellant / Revenue) (Respondent / Assessee) Pan: Aabcr 8097 G Revenue By Shri Ashish Porwal, Sr. Dr Assessee By Shri Deepak Mantri, Ar Date Of Hearing 28.02.2023 Date Of Pronouncement 28.03.2023

disallowance. 5. Per contra, Ld. AR submitted that the assessee-company is in fact engaged in the business of “generation of power” which is captively consumed. He submitted that in order to be eligible for deduction, engagement in “generation of power” is sufficient and it is not necessary to undertake all activities such as “generation or generation and distribution

MADHYA PRADESH ROAD DEVELOPMENT CORPORATION LIMITED,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX ACIT-2(1), BHOPAL

In the result appeal of the assesse is allowed for statistical purpose

Bench: Shri B.M. Biyani & Shri Paresh M Joshimadhya Pradesh Road Acit-2(1), बनाम/ Development Corporation Bhopal Vs. Ltd, 45-A, Arera Hiils, Bhopal (Pan:Aagcm5306C) (Assessee/Appellant) (Revenue/Respondent) Assessee By Shri Vikas Guru, Ar Revenue By Shri Ashish Porwal, Dr Date Of Hearing 24.09.2025 Date Of Pronouncement 30.09.2025 आदेश / O R D E R

section 250 of the Act that date and place of hearing was duly fixed. The assessee was also given notice along with notice to the Assessing Officer. The assessee had ample opportunity to make his submissions by appearing in person or through authorized representative. Despite fixing the case for seventeen hearings, no one had put in appearance nor any justifiable

SHRI DILIP BUILDCON LTD,BHOPAL vs. DCIT CENTRAL -1, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DCIT (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LTD., BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL vs. DILIP BUILDCON LIMITED, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

THED CIT ,CENTRAL-1, BHOPAL vs. M/S DILIP BUILDCON LTD, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DILIP BUILDCON LTD.,BHOPAL vs. DCIT (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DILIP BUILDCON LIMITED,BHOPAL vs. DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL)-1, BHOPAL

In the result, revenue’s appeal for A

Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&

801A(4) which reads as under, makes the position very clear : 'Explanation : For the removal of doubts, it is hereby declared that nothing contained in this section shall apply in relation to a business referred to in sub-section (4) which is in the nature of a works contract awarded by any person (including the Central or State Government

DCIT 3 (1), BHOPAL vs. M/S NHDC LTD, BHOPAL

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri B.M. Biyani (Accountant Member)

Section 801A calls for exclusion of the tax component in the sale price of electricity. Consequently, the first question raised in the tax case is answered in favour of the assessee and the order of the Tribunal is set aside." 10. The Ld Counsel further submitted that this judgement was followed by Hon’ble Madras High Court in the case