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

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

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHOPOAL, BHOPAL vs. M/S RASHTRIYA TAKNIKI SHIKSHAK PRASHIKSHAN EVAM ANUNSANDHAN SANSTHAN, BHOPAL

Appeal is dismissed

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

40A(7). The AO finalized assessment of assessee by way of scrutiny u/s 143(3) and in the assessment so finalized, the assessee’s claim remained allowed. Subsequently, the AO re-opened assessee’s case u/s 147 and during proceeding of re-assessment disallowed assessee’s claim which the assessee accepted. However, the AO imposed penalty u/s 271

PRASAM RAKESH CHOUDHARY,GIRNAR SOCIETY, BAPURAO GALLI, ITWARI, NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, BHOPAL , BHOPAL

Appeal is dismissed

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

40A(7). The AO finalized assessment of assessee by way of scrutiny u/s 143(3) and in the assessment so finalized, the assessee’s claim remained allowed. Subsequently, the AO re-opened assessee’s case u/s 147 and during proceeding of re-assessment disallowed assessee’s claim which the assessee accepted. However, the AO imposed penalty u/s 271

M/S PUMARTH INFRASTRUCTURE PRIVATE LIMITED,INDORE vs. THE ASSTT COMMISSIONER OF INCOME TAX CIRCLE 4(1), AAYKAR BHAWAN, INDORE

Appeals are allowed for statistical purposes

u/s 271(1)(c) of the Income Tax Act, 1961\nconsidering the concealment of income of Rs. 24,19,200/- and levied penalty\nof Rs. 8,00,000/-. The penalty so levied by the Ld. AO is in accordance with\nthe provision made under Income Tax Act, 1961 and is found to be in order.\nFurther, the contention

M/S PUMARTH INFRASTRUCTURE,INDORE vs. THE ASST COMMISSIONER IF INCOME TAX CIRCLE 4(1), AAYKAR BHAWAN , INDORE

Appeals are allowed for statistical purposes

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

40A(3) 4,94,220 75,340 14,90,150 Assessed income 1,08,40,970 5,18,15,540 1,31,01,170 (iii) Against quantum-assessments so made, the assessee carried matters in first-appeals before CIT(A) and contested the additions/ disallowances made by AO. The CIT(A) granted part-relief. Still aggrieved, the assessee carried matters

M/S PUMARTH INFRASTRUCTURE PRIVATE LIMITED,INDORE vs. THE ASSTT COMMISSIONER OF INCOME TAX CIRCLE - 4(1), AAYKAR BHAWAN, INDORE

Appeals are allowed for statistical purposes

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

40A(3) 4,94,220 75,340 14,90,150 Assessed income 1,08,40,970 5,18,15,540 1,31,01,170 (iii) Against quantum-assessments so made, the assessee carried matters in first-appeals before CIT(A) and contested the additions/ disallowances made by AO. The CIT(A) granted part-relief. Still aggrieved, the assessee carried matters

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

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

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

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

DHANRAJ DISTRIBUTORS (P) LTD.,INDORE vs. DCIT (1), INDORE

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

271(1)(c) of the Income Tax Act, 1961 [“the Act”], the assessee has filed this appeal on the following grounds: “1. The penalty levied by AO is null and void as the notice issued is vague as to concealment of income or furnishing inaccurate particulars of income. 2. The penalty levied by AO is null and void

SHAHANSHAH DAL MILL,BHOPAL vs. ITO-5(3), BHOPAL, BHOPAL

Appeal is dismissed

penalty u/s\n271(1)(c) is hereby initiated.\n(v)\nAggrieved, the assessee carried matter in first-appeal but did not file\nany response to the notices of hearing issued by CIT(A). The CIT(A),\nvide order dated 31.01.2023, dismissed assessee's appeal and upheld\nthe disallowance made by AO.\n(vi)\nStill aggrieved, the assessee has come

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

271, howsoever grave the suspicion the AO may entertain, the suspicion cannot take place of the evidence or finding of fact. The suspicion on the AO’s part can certainly prompt him to conduct enquiry & investigation but ultimate finding of the authority must be based on the material or evidences gathered by him and which has live nexus with

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

271, howsoever grave the suspicion the AO may entertain, the suspicion cannot take place of the evidence or finding of fact. The suspicion on the AO’s part can certainly prompt him to conduct enquiry & investigation but ultimate finding of the authority must be based on the material or evidences gathered by him and which has live nexus with