AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

u/s 263 of the Act must have been taken within the period of limitation. Ld. DR has contended that after the reassessment order dated 03.03.2016 was set aside by the Ld. CIT the same has merged with the subsequent order dated 31st July 2017. However, the said doctrine of merger would not apply beyond the subject matter of revision 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

loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which

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

loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which

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

loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which

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

loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which

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

loss or the depreciation allowance or any other allowance or deduction for such assessment year (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-1, INDORE vs. SHRI RITESH JAIN, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani & It(Ss)Ano.14/Ind/2022 (Assesssment Year 2011-12

reassessment framed by the AO u/s 147 r.w. section 143(3) without a valid notice u/s 143(2) is not valid and liable to be quashed as held by the Hon’ble Supreme Court in case of ACIT vs. Hotel Blue Moon 321 ITR 362. 7. The next objection of the assessee is against the validity of the order passed

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

147 of the Act and the Tribunal quashed those reassessment proceedings. It is not necessary M/s.Sheetu Educational Services P.Ltd. I.T.A.Nos. 24 to 26/Ind2015 and 352 to 354/Ind/2016 Page 56 of 66 to go into the question as to whether reassessment proceedings were initiated or not inasmuch as on merit itself we have decided that such an addition was not proper

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

147 of the Act and the Tribunal quashed those reassessment proceedings. It is not necessary M/s.Sheetu Educational Services P.Ltd. I.T.A.Nos. 24 to 26/Ind2015 and 352 to 354/Ind/2016 Page 56 of 66 to go into the question as to whether reassessment proceedings were initiated or not inasmuch as on merit itself we have decided that such an addition was not proper

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

147 of the Act and the Tribunal quashed those reassessment proceedings. It is not necessary M/s.Sheetu Educational Services P.Ltd. I.T.A.Nos. 24 to 26/Ind2015 and 352 to 354/Ind/2016 Page 56 of 66 to go into the question as to whether reassessment proceedings were initiated or not inasmuch as on merit itself we have decided that such an addition was not proper

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

147 of the Act and the Tribunal quashed those reassessment proceedings. It is not necessary M/s.Sheetu Educational Services P.Ltd. I.T.A.Nos. 24 to 26/Ind2015 and 352 to 354/Ind/2016 Page 56 of 66 to go into the question as to whether reassessment proceedings were initiated or not inasmuch as on merit itself we have decided that such an addition was not proper

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

147 of the Act and the Tribunal quashed those reassessment proceedings. It is not necessary M/s.Sheetu Educational Services P.Ltd. I.T.A.Nos. 24 to 26/Ind2015 and 352 to 354/Ind/2016 Page 56 of 66 to go into the question as to whether reassessment proceedings were initiated or not inasmuch as on merit itself we have decided that such an addition was not proper

THE ACIT, 3(1), INDORE vs. M/S. KALANI INDUSTRIES PVT. LTD., INDORE

In the result appeals of the revenue & assessee are

Bench: Shri Kul Bharat & Shri Manish Borad

loss. 06.That the appellant craves leave to add, alter and/ or delete any of the grounds of appeal. The Revenue has raised following grounds of appeal in ITANos.448/Ind/2018 ( M/s Flexituff International Ltd.): 1. On the facts and in the circumstances of the case and in law, whether the Ld. CIT- (A) of justified in deleting disallowance

DCIT, 3(1), INDORE vs. M/S. KALANI INDUSTRIES PVT. LTD., INDORE

In the result appeals of the revenue & assessee are

Bench: Shri Kul Bharat & Shri Manish Borad

loss. 06.That the appellant craves leave to add, alter and/ or delete any of the grounds of appeal. The Revenue has raised following grounds of appeal in ITANos.448/Ind/2018 ( M/s Flexituff International Ltd.): 1. On the facts and in the circumstances of the case and in law, whether the Ld. CIT- (A) of justified in deleting disallowance

DCIT, 3(1), INDORE vs. M/S. KALANI INDUSTRIES PVT. LTD., INDORE

In the result appeals of the revenue & assessee are

Bench: Shri Kul Bharat & Shri Manish Borad

loss. 06.That the appellant craves leave to add, alter and/ or delete any of the grounds of appeal. The Revenue has raised following grounds of appeal in ITANos.448/Ind/2018 ( M/s Flexituff International Ltd.): 1. On the facts and in the circumstances of the case and in law, whether the Ld. CIT- (A) of justified in deleting disallowance

THE DCIT 1(1), INDORE vs. M/S FLEXITUFF INTERNATIONAL LTD., INDORE

In the result appeals of the revenue & assessee are

Bench: Shri Kul Bharat & Shri Manish Borad

loss. 06.That the appellant craves leave to add, alter and/ or delete any of the grounds of appeal. The Revenue has raised following grounds of appeal in ITANos.448/Ind/2018 ( M/s Flexituff International Ltd.): 1. On the facts and in the circumstances of the case and in law, whether the Ld. CIT- (A) of justified in deleting disallowance

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

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

loss account under the head “cost of material consumed”. 4.1 That the Ld. CIT(A) and AO was not justified in holding that the direct and production expenses claimed under various heads were to borne by the M/s. Procter and Gamble and not by assessee without looking into facts and audited balance sheet submitted during the hearing before both authorities

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

loss account under the head “cost of material consumed”. 4.1 That the Ld. CIT(A) and AO was not justified in holding that the direct and production expenses claimed under various heads were to borne by the M/s. Procter and Gamble and not by assessee without looking into facts and audited balance sheet submitted during the hearing before both authorities