M/S SHREE COAL ENTERPRISES (I) PVT. LTD.,BHOPAL vs. THE ACIT 3(1), BHOPAL

In the result, all the 12 appeals filed at the instance of

Bench: Shri Kul Bharat & Shri Manish Borad

reassessment cannot be declared as invalid in the penalty proceedings.” In the light of the above judgment we are unable to affirm the action of the authorities below. As the initiation of penalty under section 271(1)(c) vide notice 274 of the Act is not inconformity with the requirement of the law. Thus, the Penalty order

M/S KETI SANGHAM INFRASTRUTURE (I) LIMITED,INDORE vs. DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL), INDORE

In the result, all the 12 appeals filed at the instance of

Bench: Shri Kul Bharat & Shri Manish Borad

reassessment cannot be declared as invalid in the penalty proceedings.” In the light of the above judgment we are unable to affirm the action of the authorities below. As the initiation of penalty under section 271(1)(c) vide notice 274 of the Act is not inconformity with the requirement of the law. Thus, the Penalty order

ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

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

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

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

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

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

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

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

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

ASSISSTANT COMMISSIONER OF INCOME TAX - 4(1), INDORE, INDORE vs. PRATAAP SNACKS LIMITED, INDORE

In the result revenue’s appeal is dismissed and assessee’s cross-objection is allowed

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

reassessment order passed u/s 147 of the Act. The Cross Objections of the assessee stand disposed off being allowed. Revenue’s Appeal for A.Y. 2012-13, 2013-14, 2017-18, 2020- 21 and 2018-19: 11. Ld. Departmental Representative vehemently argued and submitted that section 80IB(11A) provides for deduction in the case of an undertaking deriving profit from

INCOME TAX OFFICER , RAISEN, RAISEN vs. LATE SUDHA AGRAWAL TH. L/H MANMOHAN AGRAWAL, RAISEN

Appeal is dismissed and assessee’s cross-

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniincome-Tax Officer, Late Smt. Sudha Agrawal, बनाम/ Raisen (L/H: Manmohan Agrawal) Vs. 19/1, Shreeji Enterprise, Near Sbi, Sagar Road, Yashwant Nagar, M.P. (Pan: Abfpa4355G) (Revenue/Appellant) (Assessee/Respondent)

56,62,810/- after making addition of long-term capital gain. Aggrieved, the assessee carried matter in first-appeal and challenged AO’s order on twin-counts of invalidity as well as merit. The CIT(A) decided assessee’s appeal vide order dated 22.06.2023 allowing both claims of assessee and thereby giving full relief. Now, the revenue has come

M/S SHEETU EDUCATIONAL SERVICE PVT LTD.,INDORE vs. THE DCIT 5(1), INDORE

In the result, all the appeals of the assessee for assessment year 2005-06 to 2010-11 are partly allowed as per our

Bench: Shri D.T. Garasia & Shri O.P. Meena

viii) Tara Chand Jain, I.T.A.No. 2282/Kol/2014 ( I.T.A.T. Kol.) (ix) Gas & Power Investment Co., (Appeal No. I.T.A.No. 1118/Mum/2014 dated 5.2.2016 ( I.T.A.T. Mum.) 9. The ld. Authorized Representative of the assessee further contended that the above reasons were recorded by the AO on the basis of Balance Sheet of the assessee and no new tangible material came into the notice

M/S SHEETU EDUCATIONAL SERVICE PVT LTD.,INDORE vs. THE DCIT 5(1), INDORE

In the result, all the appeals of the assessee for assessment year 2005-06 to 2010-11 are partly allowed as per our

Bench: Shri D.T. Garasia & Shri O.P. Meena

viii) Tara Chand Jain, I.T.A.No. 2282/Kol/2014 ( I.T.A.T. Kol.) (ix) Gas & Power Investment Co., (Appeal No. I.T.A.No. 1118/Mum/2014 dated 5.2.2016 ( I.T.A.T. Mum.) 9. The ld. Authorized Representative of the assessee further contended that the above reasons were recorded by the AO on the basis of Balance Sheet of the assessee and no new tangible material came into the notice

M/S. SHEETU EDUCATIONAL SERVICES P. LTD.,INDORE vs. THE DCIT 5(1), INDORE

In the result, all the appeals of the assessee for assessment year 2005-06 to 2010-11 are partly allowed as per our

Bench: Shri D.T. Garasia & Shri O.P. Meena

viii) Tara Chand Jain, I.T.A.No. 2282/Kol/2014 ( I.T.A.T. Kol.) (ix) Gas & Power Investment Co., (Appeal No. I.T.A.No. 1118/Mum/2014 dated 5.2.2016 ( I.T.A.T. Mum.) 9. The ld. Authorized Representative of the assessee further contended that the above reasons were recorded by the AO on the basis of Balance Sheet of the assessee and no new tangible material came into the notice

M/S. SHEETU EDUCATIONAL SERVICES P. LTD.,INDORE vs. THE DCIT 5(1), INDORE

In the result, all the appeals of the assessee for assessment year 2005-06 to 2010-11 are partly allowed as per our

Bench: Shri D.T. Garasia & Shri O.P. Meena

viii) Tara Chand Jain, I.T.A.No. 2282/Kol/2014 ( I.T.A.T. Kol.) (ix) Gas & Power Investment Co., (Appeal No. I.T.A.No. 1118/Mum/2014 dated 5.2.2016 ( I.T.A.T. Mum.) 9. The ld. Authorized Representative of the assessee further contended that the above reasons were recorded by the AO on the basis of Balance Sheet of the assessee and no new tangible material came into the notice

M/S. SHEETU EDUCATIONAL SERVICES P LTD.,INDORE vs. THE DCIT 5(1) RANGE-5, INDORE

In the result, all the appeals of the assessee for assessment year 2005-06 to 2010-11 are partly allowed as per our

Bench: Shri D.T. Garasia & Shri O.P. Meena

viii) Tara Chand Jain, I.T.A.No. 2282/Kol/2014 ( I.T.A.T. Kol.) (ix) Gas & Power Investment Co., (Appeal No. I.T.A.No. 1118/Mum/2014 dated 5.2.2016 ( I.T.A.T. Mum.) 9. The ld. Authorized Representative of the assessee further contended that the above reasons were recorded by the AO on the basis of Balance Sheet of the assessee and no new tangible material came into the notice

NILIMA KOTHARI,INDORE vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSTT. CENTRE, INDORE

In the result appeal of the assessee is allowed as per terms indicated above

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

viii) The time limitation for issuance of notice under section 148 of the Act is proposed to be provided in section 149 of the Act and is as below: • in normal cases, no notice shall be issued if three years have elapsed from the end of the relevant assessment year. Notice beyond the period of three years from

JCIT(OSD),-2(1),INDORE, INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

THE DCIT, 2(1), INDORE vs. SHRI KESHAV KUMAR NACHANI, INDORE

In the result, all the appeals of the Revenue are dismissed

Bench: Smt. Madhumita Roy & Shri Bhagirath Mal Biyani

reassessment of the firm under section 143(3) read with section 148 wherein the impugned share of profit was offered to tax was completed and accepted by the Revenue. There is no material with the AO to demonstrate that firm was not genuine, and its activities were doubtful nature, and that the impugned amount of Rs.25,76,208/- represented unexplained

SITARAM MUCHHALA,MARDANA vs. ITO KHARGONE, KHARGONE

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

56, made to the income of the appellant. 3. On the facts and circumstances of the case and in law, the NFAC Order dated 13.03.2025 is contrary to law, facts and circumstances of the case and in any case is opposed to the principles of equity, natural justice and fair play. Page 7 of 13 Sitaram Muchhala ITA No. 661/Ind/2025