M/S SHREE JAIRAM EDUCATION SOCIETY,BHOPAL vs. PR. CIT (CENTRAL), BHOPAL

In the result, appeal of the assessee in ITANo

Bench: Hon’Ble Rajpal Yadav & Shri Manish Boradvirtual Hearing

148 dated 28.03.2017 are unlawful, bad in law and without jurisdiction hence the assessment made be kindly cancelled. 2. That on the facts & in the circumstances of the case and in law, the learned lower authorities erred and in not justified in assessing the income of the assessee as the income from business and profession

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

148 after expiry of four years from end of assessment- year. Now, in this circumstance, the assessee is pressing the bar imposed in first proviso to section 147 according to which the AO cannot take action against assessee unless there is a case of assessee’s failure to disclose fully and truly all material facts necessary for assessment. The proviso

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

Transfer Pricing Officer, as the case may be, had been the subject-matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as had not been considered and decided

M/S. BRIDGESTONE INDIA PVT. LTD.,PUNE vs. THE ACIT NFAC, DELHI

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibridgestone India Pvt. Ltd. Acit (Nfac) Plot No.A-43, Phase-Ii, Delhi Midc Chakan, Village Vs. Sawardari, Taluka Khed, Pune (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabcb 2304 E Assessee By Shri Sukhsagar Syal, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 23.05.2023 Date Of Pronouncement 17.07.2023

transfer pricing documentation and economic analysis has passed an order dated 30.10.2018 under Section 92CA(3) of the Act determining the "Arm's Length Price" difference of Rs. 41,57,14,9471- in respect of royalty payment of its AE and Rs. 39,63,921/- in respect of international transactions relating to trading activities of the assessee. Thus, total upward

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

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

148 of the Act and on the basis of the same set of analysis of trade data and enquiries of the brokers conducted by the Investigation Wing Ahmedabad and the losses incurred by the assessee in commodity transactions conducted on the NMCE platform were disallowed. The disallowances were deleted in the first appeal and the department filed second appeal before

SANJEEV AGRAWAL ,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL-2, BHOPAL

Appeal is allowed

Price Waterhouse & Co Vs. Deputy Commissioner of Income\nTax, Circle-22, ITA No. 1985/Kol2018 Order dated 5/2/2020, it\nwas observed:-\n“11. Therefore, in the light of the aforesaid judicial precedents and other case\nlaws, we note that to initiate reopening of the assessment, the Ld. AO must\nhave 'reason to believe that income chargeable to tax has escaped assessment

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

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. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

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

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. 4.2.2 After considering the observation made in the assessment order and also taking into consideration the written submissions

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

1 kgm Silver bar was sold with a profit in the range of Rs. 500'/- to Rs 800/- during the reference year. In view of the above, gross profit earned on sale of per Silver bar is determined at Rs. 800/- In this regard the reply given for Gross Profit estimation in case of Gold KG Bars is equally applicable

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

1 kgm Silver bar was sold with a profit in the range of Rs. 500'/- to Rs 800/- during the reference year. In view of the above, gross profit earned on sale of per Silver bar is determined at Rs. 800/- In this regard the reply given for Gross Profit estimation in case of Gold KG Bars is equally applicable

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

1 kgm Silver bar was sold with a profit in the range of Rs. 500'/- to Rs 800/- during the reference year. In view of the above, gross profit earned on sale of per Silver bar is determined at Rs. 800/- In this regard the reply given for Gross Profit estimation in case of Gold KG Bars is equally applicable