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

disallowance of Rs.6,07,00,658/- made under Section 14A as per rule 8D. Also for upward adjustment of Rs.212,56,79,027/- on account of software services. The DRP confirmed the same. The Assessing Officer vide Assessment Order dated 05.02.2016 made addition of Rs.220,97,90

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

disallowance of Rs.6,07,00,658/- made under Section 14A as per rule 8D. Also for upward adjustment of Rs.212,56,79,027/- on account of software services. The DRP confirmed the same. The Assessing Officer vide Assessment Order dated 05.02.2016 made addition of Rs.220,97,90

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

disallowance of deduction claimed under sections 10AA, 80IA,, 80-IAB, 80IB, 80-IC, 80-ID or section 80IE, if the return is furnished beyond the due date specified under sub-section (1) of section 139; ,or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income

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

disallowance of deduction claimed under sections 10AA, 80IA,, 80-IAB, 80IB, 80-IC, 80-ID or section 80IE, if the return is furnished beyond the due date specified under sub-section (1) of section 139; ,or (vi) addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income

MAHENDRA KUMAR PANDYA ,INDORE vs. DCIT/ACIT 1(1), IND, INDORE

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

disallowed the relief of Rs. 21,98,470/- claimed under section 90 on the Income of Rs. 92,06,321/- earned

JILA SAHAKARI KENDRIYA BANK MYDT,SEHORE, MP vs. COMMISIONER OF INCOME TAX (APPEALS), NFAC, DELHI

Appeal is partly allowed for statistical purposes

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Jila Sahakari Kendriya Cit(A), Nfac, Delhi / Bank Mydt, Acit-3(1), Bhopal बनाम/ Sehore, M.P. Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaalj0022F Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 26.02.2026 Date Of Pronouncement 10.04.2026

90,950/- and subsequently filed a revised return on 15.12.2014 declaring a total income of Rs. 6,88,16,920/-. The case was selected for scrutiny under CASS and the AO issued notices u/s 143(2)/142(1). Finally, the Ld. AO completed assessment u/s 143(3) at a total income of Rs. 7,83,44,630/- after making three

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

disallowance u/s 14A”. Decision of Honorable High Court of Delhi in the case of CIT v/s. M/s. Holcim India P. Ltd. (2014) 90 CCH 0081 Del HC. Relying upon on the decision rendered by the Punjab and Haryana High Court in CIT Vs. M/s. Lakhani Marketing Incl. ITA No. 970/2008, in which the Honorable court has made reference

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

90,000/-, the disallowance ultimately directed works out to nearly 110% of that sum, i.e., Rs.52,56,197/-. By no stretch of imagination can 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

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

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

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

SRK DEV BUILD PVT LTD.,INDORE vs. DCIT/ACIT 5(1), INDORE

Appeal is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 Srk Dev Build Pvt. Ltd, Dcit/Acit-5(1) 18/2, Lasudia Mori, Indore बनाम/ A.B. Road, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aaqcs3387P Assessee By Shri Pranay Goyal & S.N. Goyal, Cas Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 15.04.2024 Date Of Pronouncement 20.06.2024

90,33,182/- cannot be considered as incidental to the business of the assessee. Therefore, cannot be allowed as business expenses. In view of the above there is no change of opinion. 3.4 In the case of Sambhav Media Limited, the assessee has claimed double deduction of depreciation on business asset while in this case the assessee has not used

BHOPAL SWITCHGEARS (P) LTD.,BHOPAL vs. THE D C I T 1(1) BHOPAL, BHOPAL

In the result, this appeal of assessee is partly allowed

Bench: Ms. Madhumita Roy & Shri B.M. Biyaniassessment Year: 2012-13 Bhopal Switchgears P. Ltd. Dcit -1(1) Bhopal बनाम/ Bhopal Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Aaacb 6092 J Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 20.09.2022 Date Of Pronouncement 23.09.2022

90,876/- sustained by Ld. CIT(A). Ground No. 1 of assessee, therefore, succeeds. Ground No. 2: 7. This Ground relates to the disallowance of donation of Rs. 12,101/-. Ld. AO has mentioned that the donation-expenditure is not allowable u/s 37(1) of the Act. Ld. CIT(A) has sustained addition for the reason that no specific-submission

THE DCIT, 1(1), INDORE vs. M/S. MODERN LABORATORIES, INDORE

In the result, the CO of the assessee is partly allowed

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./ ./ ./ I.T.A. No.277 & Co.16/Ind/2014 ./ "नधा"रण वष" /Assessment Year:2008-09

section 68 of the Act keeping aside all the DCIT v 1(1) v Modern Laboratories / I. T. A. No. 277/Ind/2014& CO.No.16/Ind/2014/AY:08-09 Page 24 of 29 relevant documents, which were filed by the assessee and the alleged companies. Accordingly, we have no hesitation to hold that we are unable to see any ambiguity, perversity or any other

DEPUTY COMMISSIONER OF INCOME TAX-12(1), INDORE vs. M/S CPR DISTRIBUTORS P.L., INDORE

In the result Ground No.2 of the revenue’s appeal is dismissed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2011-12 Dcit-2(1), M/S. Cpr Distributors Indore Vs. Pvt. Ltd (M.P), 13, Sneh Nagar, Sapna Sangeeta, Indore (Revenue) (Respondent ) Pan No.Aabcc8324M

Section 40A(2)(b) of the Act and the Ld. A.O has rightly disallowed the expenses. 8. We have heard rival contentions and perused the records placed before us. Revenue’s grievance in Ground No.1 is against the finding of Ld. CIT(A) deleting the disallowance of commission expenses of Rs.67,00,000/-. We observe that the assessee

SHRI SUSHIL KUMAR BAFNA,UJJAIN vs. THE ITO 1(1), UJJAIN

In the result, the appeal of the assessee is partly allowed

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./ I.T.A. No. 637/Ind/2014 "नधा"रण वष" /Assessment Year: 2010-11

disallowing the claim of deduction made under section 54F amounting to Rs. 99,40,150/- and in making addition of the said amount to income under the head Long Term Capital Gain. That on the facts and circumstances of the case, the disallowance/addition made is wrong and bad in law and it is prayed that the said deduction may very

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

disallowing expenditure towards earning of such income, under section 14A, whereas, no expenditure was in fact incurred by the assessee towards earning such income. 25. The ld. AO has erred in computing interest u/s 234B of the Act on the assessed income since the addition to the returned income on account of Transfer Pricing adjustment is only a notional income