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

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

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

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

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

DINESH RAMNANI,NEEMUCH vs. ITO, NEEMUCH

In the result, the appeal of the assesse is allowed for statistical purposes

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanidinesh Ramnani Ito 28, Gayatri Mandir Road Delhi Vs. Neemuch (Appellant / Assessee) (Revenue) Pan: Aehpr 9729L Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.11.2023 Date Of Pronouncement 23.11.2023

Section 44AD and disallowance of commission expenses amounting to Rs. 40,90,292/- is arbitrary, unjustified, unwarranted, factually and legally

RAJKUMAR GOYAL,INDORE vs. THE PR. CIT-2, INDORE

In the result, appeal of the assesse is dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniraj Kumar Goyal Pr. Cit-2 42, Narmda Marg Barwaha Indore Vs. Khargone (Appellant / Assessee) (Revenue) Pan: Ackpg 1896N Assessee By Shri Ram Gilda, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.09.2023 Date Of Pronouncement 20.11.2023

90,022/- as a statutory liability till the date under section 139(1) of the IT. Act. In the computation of income neither you have added back nor AO has disallowed

ANDRITZ HYDRO P LTD,BHOPAL vs. PR CIT-1, BHOPAL

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing

90,30,000 Disallowed AY 2008-09 1,16,01,000 Disallowed AY 2009-10 (Pre- Merger) 64,18,000 Disallowed As on 31 December 2008 5,10,50,999 From above, we find that the Prithla Unit had created a provision of Rs. 5,10,50,999/- which was not claimed as a deduction in the year of creation

MRS. JATINDER KAUR BHATIA,KHANDWA vs. ACIT- (CENTRAL) UJJAIN, UJJAIN

Appeals are dismissed and assessee’s

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

section 40A(3). Thus, considering entire conspectus of case, we do not find any valid reason to make interference with the deletion of disallowance made by CIT(A). Consequently, we uphold order of CIT(A) and the grounds raised by revenue are dismissed. Page 14 of 46 Mrs. Jatinder Kaur Bhatia ITA Nos. 206 & 207/Ind/2023 & ITANo.227/Ind/2023

DCIT- (CENTRAL)-3, INDORE vs. MRS. JATINDER KAUR BHATIA, KHANDWA

Appeals are dismissed and assessee’s

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

section 40A(3). Thus, considering entire conspectus of case, we do not find any valid reason to make interference with the deletion of disallowance made by CIT(A). Consequently, we uphold order of CIT(A) and the grounds raised by revenue are dismissed. Page 14 of 46 Mrs. Jatinder Kaur Bhatia ITA Nos. 206 & 207/Ind/2023 & ITANo.227/Ind/2023

DCIT- (CENTRAL)-3, INDORE vs. MRS. JATINDER KAUR BHATIA, KHANDWA

Appeals are dismissed and assessee’s

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

section 40A(3). Thus, considering entire conspectus of case, we do not find any valid reason to make interference with the deletion of disallowance made by CIT(A). Consequently, we uphold order of CIT(A) and the grounds raised by revenue are dismissed. Page 14 of 46 Mrs. Jatinder Kaur Bhatia ITA Nos. 206 & 207/Ind/2023 & ITANo.227/Ind/2023

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

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

90,297/- 3. Disallowance of Registration Expenses Rs. 89,96,634/- 4. Disallowance of purchase Rs.3,04,29,100/- 5. Disallowance of training expenses Rs.8,14,42,700/- Rs.12,20,19,196/- Aggrieved Assessee preferred appeal before Ld. Cit(A) and partly succeeded. 9. Now both the assessee and Revenue are in appeal before the Tribunal challenging the finding

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

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

90,297/- 3. Disallowance of Registration Expenses Rs. 89,96,634/- 4. Disallowance of purchase Rs.3,04,29,100/- 5. Disallowance of training expenses Rs.8,14,42,700/- Rs.12,20,19,196/- Aggrieved Assessee preferred appeal before Ld. Cit(A) and partly succeeded. 9. Now both the assessee and Revenue are in appeal before the Tribunal challenging the finding

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

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

90,297/- 3. Disallowance of Registration Expenses Rs. 89,96,634/- 4. Disallowance of purchase Rs.3,04,29,100/- 5. Disallowance of training expenses Rs.8,14,42,700/- Rs.12,20,19,196/- Aggrieved Assessee preferred appeal before Ld. Cit(A) and partly succeeded. 9. Now both the assessee and Revenue are in appeal before the Tribunal challenging the finding

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

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

90,297/- 3. Disallowance of Registration Expenses Rs. 89,96,634/- 4. Disallowance of purchase Rs.3,04,29,100/- 5. Disallowance of training expenses Rs.8,14,42,700/- Rs.12,20,19,196/- Aggrieved Assessee preferred appeal before Ld. Cit(A) and partly succeeded. 9. Now both the assessee and Revenue are in appeal before the Tribunal challenging the finding

JYOTI GOYAL,BHOPAL vs. DCIT-1(1), BHOPAL

Appeal is partly allowed as mentioned above

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2012-13 Jyoti Goyal, Dcit, 18, Shyamla Hills, 1(1), बनाम/ Bhopal Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abbpg3493P Assessee By Shri S.S. Deshpande, Ca & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 25.04.2024 Date Of Pronouncement 20.05.2024

disallowance of addition of Rs. 90,75,000/- invoking provision of section 56(2)(vii) and or 28(iv) of the Act. (3) That

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 80-IA,\nrule 18BBB and proviso to rule 12(2). Accordingly, the AO disallowed\nassessee's claim of deduction of Rs.8,60,92,248/- u/s 35AD and re-\ndetermined total income at Rs.87,45,121/-. Further, the AO re-\ndetermined deemed total income of assessee u/s 115JC at Rs.\n31,90

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

90,34,341/- determined by the Assessing Officer in the assessment order even when the said amount of capital gain was duly examined by the Assessing Officer at the time of original assessment proceedings. 4. The appellant reserves the right to add, alter and modify the grounds of appeal as taken by him. ” 10. The assessment u/s 143(3) r.w.s