SUNAYANA INVESTMENT COMPANY LTD,INDORE vs. PCIT-1, INDORE, INDORE

The appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisunayana Investment Company Pcit-1, Ltd, Indore Part-B Of 417 Chetak Centre Annex, Vs. R.N.T. Marg, Near Hotel Shreemaya, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaucs5765M Assessee By Shri Sohit Gupta & Ms. Alifiya Ali, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 08.10.2024 Date Of Pronouncement 11.10.2024 O R D E R

147 3 Sunayana Investment Company Limited of the Act on 27.03.2023 on a different PAN not belonging to the assessee. Therefore, this issue of alleged accommodation entry of Rs.5,00,000/- received from M/s Orange Mist Production Pvt. Ltd was not a subject matter of reassessment proceedings and cannot be taken up in the revision proceedings u/s 263

NARENDRA KUMAR AGRAWAL,BURHANPUR vs. PCIT INDORE-1, INDORE

In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaninarendra Kumar Agrawal Pcit (1) 203, Ck Campus Aaykar Bhawan Bahadarpur Road Vs. Indore Burhanpur (Appellant / Assessee) (Respondent/ Revenue) Pan: Adapa0131B Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 20.08.2024 Date Of Pronouncement 29.08.2024

reassessment proceedings with specific queries on the same issue. Thereafter the Pr. CIT has issued show cause notice u/s 263 on 22.02.2024 placed at page no.45 to 47 of the paper book as under: “M/s/Mr/Ms Subject: Notice for Hearing in respect of Revision proceedings uls 263 of the THE INCOME TAX ACT, 1961-Assessment Year 2016-17. In this

S GANDHI JEWELLERY PRIVATE LIMITED,INDORE vs. PCIT-1, INDORE, INDORE

Appeal is allowed

Bench: Shri B.M. Biyani & Shri Dinesh Mohan Sinhaassessment Year: 2017-18 S. Gandhi Jewellery Pcit-1, Private Limited, Indore C/O Adv. Hitesh Chimnani, बनाम/ Ug-37 Trade Centre, Vs. 18, South Tukoganj, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aamcs1613G Assessee By Shri Hitesh Chimnani, Ar Revenue By Shri Ram Kumar Yadav, Sr. Dr Date Of Hearing 10.02.2025 Date Of Pronouncement 21.02.2025

revision u/s 263 due to three-fold reasons. These reasons are very succinctly narrated by Ld. AR in Para 13 of his Written-Synopsis, we re-produce the same: “13. In this respect, the brief submissions of the assessee are as follows: 1. The assumption of jurisdiction by the Ld. PCIT on 23.02.2024 when an appeal had been filed

THE NIMAR EDUCATIONAL SOCIETY,KHANDWA vs. THE CIT (EXEMPTION), BHOPAL, BHOPAL

Appeal is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 The Nimar Educational Cit(Exemption) , Society, Bhopal बनाम/ Harsud Road, Civil Lines, East Nimar, Vs. Khandwa (Assessee/Appellant) (Revenue/Respondent) Pan: Aabtt1409K Assessee By Shri S.N. Agrawal & Shri Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit Dr Date Of Hearing 20.08.2024 Date Of Pronouncement 20.09.2024

reassessments u/s 147 r.w.s. 144/144B on the issue of deposit of Rs. 17,00,000/- in bank a/c whereas the CIT(E) has initiated revisionary-action by alleging AO’s lack of examination qua the issue of exemption u/s 10(23C)(iiiad). Thus, the issue raised by CIT(E) is clearly beyond the scope of re-assessment proceeding

SMT. SHARDA,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

revised and the aforesaid land falls within 2 Kms. from the Municipal limits of Tehsil & Dist. Harda. To support our contention once again we are attaching herewith certificate Certificate in this regard issued by Office of the Municipal Corporation, Harda as Annexure –1 which has already been furnished in response to reply to notice issued u/s 142(1) wherein

SHRI PREMNARAYAN,HARSUD, KHANDWA vs. THE PCIT-1, INDORE, INDORE

In the result, appeals of the assesse in ITANo

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Premnarayan Pcit (1) 31, Somgaon Khurd, Aaykar Bhawan Harsud, Vs. Indore Khandwa (Appellant / Assessee) (Respondent/ Revenue) Pan: Cjzpp1164J Smt. Sharda Pcit (1) A/45, Naya Harsud, Aaykar Bhawan Vs. Khandwa Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Fdxps2997P Assessee By Shri S.N. Agrawal & Pankaj Mogra, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 21.08.2024 Date Of Pronouncement 30.08.2024

revised and the aforesaid land falls within 2 Kms. from the Municipal limits of Tehsil & Dist. Harda. To support our contention once again we are attaching herewith certificate Certificate in this regard issued by Office of the Municipal Corporation, Harda as Annexure –1 which has already been furnished in response to reply to notice issued u/s 142(1) wherein

LATE SMT SUSHILA BISARYA, BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, we are Shri Jignesh Lilachand Shah vs

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanilate Smt. Sushila Bisarya Pr. Cit-1 L.H. Pramod Bisarya Bhopal Vs. 125 Malviya Nagar, Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aewpb 2587 D Assessee By Shri Gagan Tiwari, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.08.2023 Date Of Pronouncement 16.08.2023

revision order whereby the assessment order passed u/s 147 r.w.s. 143(3) dated 31st July 2017 was held to be erroneous and prejudicial to the interest of the revenue and consequently set aside u/s 263 with the direction to the AO to make afresh assessment order after giving reasonable opportunity of being heard to the assesse. Aggrieved

ANAMIKA GARG ,DEWAS vs. CIT, UJJAIN

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2015-16 Smt. Anamika Garg, Pcit, 117, Tukoganj Marg, Ujjain बनाम/ Nayapura, Vs. Dewas (Assessee / Appellant) (Revenue / Respondent) Pan: Aiwpg 3922 D Assessee By Shri Suresh Gupta, Ar Revenue By Ms. Simran Bhullar, Cit Dr Date Of Hearing 02.11.2023 Date Of Pronouncement 02.01.2024

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

M/S M.P.WAREHOUSING & LOGISTIC CORPORATION,BHOPAL vs. THE PR CIT-1, BHOPAL

In the result, the appeal is allowed

Bench: Ms. Suchitra Kamble & Shri B.M. Biyaniassessment Year: 2015-16 M/S M.P. Warehousing Pr. Cit-1 & Logistic Corporation, Bhopal बनाम/ Office Complex, Block-1, Gautam Nagar, Vs. Bhopal (Appellant / Assessee) (Respondent / Revenue) Pan: Aadcm 7742 B Assessee By Shri S.S. Deshpande, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 20.03.2023 Date Of Pronouncement 31.03.2023

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

M/S DBL JAORA SAIANA TOLLWAYA LTD,BHOPAL vs. PR CIT-1, BHOPAL

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

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under

M/S DBL BETUL SARMI TOLLWAYAS,BHOPAL vs. PR CIT-1, INDORE

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

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under

M/S DBL TIKAAMGARH NOWGON,BHOPAL vs. PR CIT -1, BHOPAL

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

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under

M/S DBL ASHOKNAGAR VIDISHA TOLLWAYS LTD,BHOPAL vs. PR CIT-1, BHOPAL

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

reassess the earlier assessment in terms of section 147 or carry out Page 8 of 10 M/s DBL vs. Pr. CIT I, Bhopal ITA Nos. 144 to 147/Ind/2020 Assessment year 2015-16 rectification u/s 154 of the Act. He can’t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under

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

263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271(1)(c) treating it as a case of furnishing inaccurate particulars by assessee. Thus, the penalty imposed by AO hinges on the point that the assessee had furnished inaccurate particulars of income by making wrong claim of depreciation. However

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

263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271(1)(c) treating it as a case of furnishing inaccurate particulars by assessee. Thus, the penalty imposed by AO hinges on the point that the assessee had furnished inaccurate particulars of income by making wrong claim of depreciation. However

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ADDL. CIT-RANGE-3, BHOPAL

In the result, appeal for A

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

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ACIT-3(1), BHOPAL

In the result, appeal for A

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

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

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

reassessment. 2. On the facts and in the circumstances of the case, the honourable CIT(A) was not justified in upholding that the receipt from job work of mixing of rubber at Rs. 34,19,894 was not the business receipts/income and in confirming the same was income from other sources. 3.On the facts and in the circumstances