THE DCIT, (EXEMPTION) CIRCLE, BHOPAL vs. M/S. MAYANK WELFARE SOCIETY, BHOPAL

In the result, Revenue’s appeal for the AY 2013-14

Bench: Shri Manish Borad & Ms. Madhumita Royvirtual Hearing Assessment Year: 2013-14

section 12A - list of honors submitted Incomplete details of donors does not mean donations are unaccounted money - Addition oj Donations as cash credit and denying benefit not justified - Income-tax Act, 1961, ss. 11, 12A, 68." 3.14 As decided in the cases of Vaishnavi Educations Society vs Deputy Commissioner of Income Tax ITAT Hyderabad Tribunal {B} {20l5

RITIKA JAIN,THANE vs. ITO(IT TP), BHOPAL, AAYKAR BHAVAN

Appeal of the assessee is allowed for statistical purpose

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshiritika Jain, Cit (Appeals), बना A-504, Laxmi Residency Chs Nfac, म/ Ltd, Delhi Vs. Opposite Datta Mandir Check Naka, Wagle Estate, Thane

249(4)(b) of the Act. The appellant has failed to do so. It is, therefore, clear that the appellant has not made payment of amount equal to the advance tax which was due on its income. 7. Since the appellant has not filed return of income as well as not paid an amount equal to the amount of advance

REKHA KHANDELWAL,RAJGARH vs. ITO WARD RAJGARH, RAJGARH

Appeal is allowed for statistical purpose

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2014-15 Rekha Khandelwal, Income-Tax Officer, Ward No.2, Near Chote Ward Rajgarh Hanuman Mandir, बनाम/ Rajgarh Bus Stand Vs. S.O. Rajgarh, (Assessee/Appellant) (Revenue/Respondent) Pan: Eljpk1548B Assessee By Shri Milind Wadhwani, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026

3. The averments made by assessee in above affidavit, which are self- explanatory and which do not require repetition, were discussed and the Ld. DR for revenue does not have any objection if the bench condones delay and accordingly left it to the wisdom of bench. We have considered the explanation advanced by assessee and in absence of any contrary

M/S RADHISHWARI DEVLOPERS P LTD,INDORE vs. PR CIT -2 INDORE, INDORE

In the result, Assessee’s appeal in ITANo

Bench: Hon’Ble Rajpal Yadav & Hon’Ble Manish Boradvirtual Hearing Assessment Year 2013-14 M/S. Radhishwari Developers P. Ltd. (Now Known As R.C. Warehousing Pvt. Ltd. ) Indore : Appellant Pan :Aafcr1916A V/S Pr. Cito-2 : Respondent Indore Appellant By S/Shri Sumit Nema Sr. Adv. With Gagan Tiwari & Piyush Parashar Advs. Revenue By Shri S.S. Mantri, Cit-Dr Date Of Hearing 24.05.2021 Date Of Pronouncement 20.07.2021

68 are fulfilled, there is hardly any scope to invoke the provisions of section 263 of the Act, alleging introduction of unexplained funds in the form of cash credits. The burden so shifts on revenue to establish that such credits has actually come from Asseessee Company itself. However, as stated above, no evidence was available on record by 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

249 (Del.) as well as decision of Delhi Benches of the Tribunal in case of Ajay Sharma vs. DCIT, ITANo.3555/Del/2015. Thus the Ld. AR has submitted that the notice u/s 143(2) was issued by the AO without even considering return of income filed by the assessee on the same date which clearly shows that the notice was ready even

SMT. SHWETA AGRAWAL,INDORE vs. THE PR. CIT-2, INDORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year:2014-15

249 416458 nt:quity 16.01201 04.03.201 22500 441450 2 eShares cPf sunrise ln1sian 13,239 23,43,676 22,10,43 Total 1,20,00 ~ You had claimed Rs.22,10,437/- as exempt L.T.C.G. in return] income filed by you . The claim has been derived from the alleged investment in the share of M/ s Sunrise Asian Limited., which

THE ACIT (CENTRAL), UJJAIN vs. M/S. VYANKTESH PLASTICS & PACKAGING (P) LTD., UJJAIN

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

249 i) No cash 412 All the payments 617 All the payments Statement of & deposit made to have been made to have been made the lender 250 by DFL before 415 by the FVPL by 622 by the NVPL making loan to obtaining either by the assessee. refunds of loans obtaining refunds from various of loans from

ACIT (CENTRAL) , UJJAIN vs. M/S. ARIBA FOODS (P) LTD., INDORE

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

249 i) No cash 412 All the payments 617 All the payments Statement of & deposit made to have been made to have been made the lender 250 by DFL before 415 by the FVPL by 622 by the NVPL making loan to obtaining either by the assessee. refunds of loans obtaining refunds from various of loans from

THE ACIT (CENTRAL), UJJAIN vs. M/S. FAMOUS VANIJYA (P) LTD. , UJJAIN

Bench: Justice P.P. Bhatt, Hon'Ble & Hon'Ble Manish Boradvirtual Hearing Assessment Year: 2016-17 M/S. Ariba Foods Pvt. Acit (Central), Vs. Ltd, 101, Gold Star Building, Ujjain Opp. Treasure Island, 5767 M.G. Road, Indore (Revenue ) (Appellant) Pan No.Aalca7223M Assessment Year: 2015-16 M/S. Vyanktesh Plastics Acit (Central), Vs. & Packaging Pvt. Ltd, 75/7-B, Industrial Area, Ujjain Maxi Road, Ujjain (Revenue ) (Appellant) Pan No.Aaacv6547J Assessment Year: 2011-12

249 i) No cash 412 All the payments 617 All the payments Statement of & deposit made to have been made to have been made the lender 250 by DFL before 415 by the FVPL by 622 by the NVPL making loan to obtaining either by the assessee. refunds of loans obtaining refunds from various of loans from

BALKISHAN KOSHAL ,INDORE vs. INCOME TAX OFFICER, NEW DELHI

Appeals are allowed for statistical

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniay: 2013-14 Shri Balkishan Koshal, Income-Tax Officer, बनाम/ 31, Bhagirathpura, Nfac, Vs. Indore. Delhi (Pan: Bkipk5435L) (Assessee/Appellant) (Revenue/Respondent) Ay: 2013-14 Shri Balkishan Koshal, Income-Tax Officer, बनाम/ 31, Bhagirathpura, Nfac, Vs. Indore. Delhi (Pan: Bkipk5435L) (Assessee/Appellant) (Revenue/Respondent)

section 68-69 of the Act, hence assessment and appeal-order is prejudice, unjustified and deserve to be set-aside according to law. I.T.A. No. 05/Ind/2024 (Penalty appeal): 1. The Ld. CIT(A), Faceless Delhi had not considered reasonable and sufficient cause to condone delay u/s 249(3

BALKISHAN KOUSHAL ,INDORE vs. INCOME TAX OFFICER, DELHI

Appeals are allowed for statistical

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniay: 2013-14 Shri Balkishan Koshal, Income-Tax Officer, बनाम/ 31, Bhagirathpura, Nfac, Vs. Indore. Delhi (Pan: Bkipk5435L) (Assessee/Appellant) (Revenue/Respondent) Ay: 2013-14 Shri Balkishan Koshal, Income-Tax Officer, बनाम/ 31, Bhagirathpura, Nfac, Vs. Indore. Delhi (Pan: Bkipk5435L) (Assessee/Appellant) (Revenue/Respondent)

section 68-69 of the Act, hence assessment and appeal-order is prejudice, unjustified and deserve to be set-aside according to law. I.T.A. No. 05/Ind/2024 (Penalty appeal): 1. The Ld. CIT(A), Faceless Delhi had not considered reasonable and sufficient cause to condone delay u/s 249(3

NETINK TECHNOLOGIES PRIVATE LIMITED,BHOPAL vs. DCIT/ACIT 3(1), BHOPAL

In the result the “impugned order” is set aside as and by

Bench: Shri B.M. Biyani & Shri Paresh M Joshinetink Technologies Dcit/Acit 3(1), बनाम/ Private Limited, Bhopal Vs. Plot No.6, Behind Congress Bhawan, Shivaji Nagar, Bhopal (Pan:Aaecn4127C) (Assessee/Appellant) (Revenue/Respondent) Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Dr Date Of Hearing 02.09.2025 Date Of Pronouncement 11.09.2025 आदेश / O R D E R

section 249(3) is sufficient cause" and not "reasonable cause". 'Sufficient cause' is much more stringent that the term 'reasonable cause' and even if a cause is reasonable, it has to be ascertained whether it was a sufficient cause or not. 5.2 On the basis of the circumstances of the case, it is held that the appellant

SATISH KUMAR RADHESHYAM CHOUDHARI,INDORE vs. INCOME TAX OFFICER, INDORE

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

249(2) of the Act.” 2.4 That in para 4 of the impugned order the Ld. CIT(A) has observed and avered as follows:- “4. According to the appellant, there is reasonable cause for filing the appeal belatedly. The delay was not willful but due to the circumstances beyond the control of the assessee. The reason stated by the appellant

M/S PLATINUM HORAZINE PVT. LTD.,INDORE vs. THE ACIT CIRCLE 3(1), INDORE

In the result, the appeal of the assessee stands

Bench: Shri Chandra Mohan Garg & Shri O.P.Meenaआ.अ.सं./ I.T.A. No.713/Ind/2016 िनधा"रण वष" /Assessment Year: 2009-10

249 of the Income Tax Act 1961 used in identical terms in the Limitation Act and the CPC. Such expression has also been used under section 4 of the Income Tax Act 1961 such as sections 273, 274 etc. The expression “’sufficient cause” within the meaning of Section 5 of Limitation Act as well as a similar

SANDEEP KUMAR YADAV,BETUL vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHO

The appeal of the appellant is dismissed for statistical purpose

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshisandeep Kumar Yadav, Nfac, बना Palsyapalsya, Delhi म/ Palsya, Vs. The. Bhainsdehi, Betul (Pan: Afnpy3295D) (Appellant) (Revenue) Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.04.2025 Date Of Pronouncement 29.04.2025 आदेश/ O R D E R

68 51,34,500/- Total income 53,33,500/- 2.10 That the aforesaid assessment order of Ld. AO bearing No. ITBA/AST/S/147/2021-22/1042015250(1) and that the same is dated 30.03.2022 which is hereinafter referred to as the “impugned assessment order.” 2.11 That the assessee being aggrieved by the “impugned assessment order” prefers first appeal u/s 246A of the Act before

M/S SHIVALIKA REALITIES P LTD,INDORE vs. ITO 5(1) , INDORE

In the result of appeals of the assessee for AY 2008-09 and AY 2009-10 vide ITA no

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing Assessment Year: 2008-09 & Assessment Year: 2009-10

249 (ASR-ITAT) [Paper Book at Page71], the ITAT, Amritsar Bench held as under : “On a perusal of section 153C, it would be clear that the provisions of this section are applicable which supersedes the applicability of provisions of sections 147 and 148. In the instant case, the documents were seized during the search under section

M/S SHIVALIKA REALITIES P LTD,INDORE vs. ITO 5(1) , INDORE

In the result of appeals of the assessee for AY 2008-09 and AY 2009-10 vide ITA no

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing Assessment Year: 2008-09 & Assessment Year: 2009-10

249 (ASR-ITAT) [Paper Book at Page71], the ITAT, Amritsar Bench held as under : “On a perusal of section 153C, it would be clear that the provisions of this section are applicable which supersedes the applicability of provisions of sections 147 and 148. In the instant case, the documents were seized during the search under section

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

68. For AY 2004-05, while deciding in favour of the assessee, the Tribunal found that there was no significant functional difference in the software development and maintenance services rendered by the assessee to its related and unrelated parties. The services rendered by the STP units of the assessee were rendered to the same AEs of the assessee, i.e., Birla