SMT. VANDANA SARAOGI,KATNI vs. PCIT(CENTRAL) BHOPAL AT JABA, JABALPUR

In the result, the appeal of the assessee is allowed

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.2016-17 Smt Vandana Saraogi Vs. Principal Commissioner Prop. Mahalaxmi Industries, Ghantaghar, Of Income Tax (Central) Hanumanganj Ward, Katni-483222. Bhopal At Jabalpur Director General Of Income Tax, Aayakar Bhawan, 48, Arera Hills, Bhopal-462011. Pan: Asips2301L (Appellant) (Respondent) Assessee By: Sh. Dhiraj Ghai, C.A. Revenue By: Sh. Shravan Kumar Meena, Cit- Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 12.12.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Pcit(Central), Bhopal At Jabalpur U/S 263 Of The Income Tax Act, 1961 (“Act”, For Short) Setting Aside The Assessment Order Passed By The Assessing Officer (Ao) U/S 153A Read With Section 143(3) Of The Act Dated 22.04.2021. The Grounds Of Appeal Are As Under:-

20,51,589/- to the file of the Ld AO without properly appreciating the explanation of assessee given during the assessment proceedings brought on record to prove that AO has deeply examined during, assessment proceedings itself. 10. The revision order dated 29.03.2024 is bad in law for other reasons also hence may kindly be cancelled.” 2. The facts

ASSISTANT COMMISSIONER OF INCOME TAX, CHHINDWARA vs. M/S. CENTRAL MADHYA PRADESH GRAMIN BANK, CHHINDWARA

In the result, the Revenue’s appeal is dismissed

gains of business or profession. In sections 28 to 41 and in this section, unless the context otherwise requires- (1) “actual cost” means the actual cost of the assets to the assessee, reduced by that portion of the cost thereof, if any, as has been met directly or indirectly by any other person or authority: Provided…. Provided further… Explanation

SMT. RASHMI PAHARIYA,JABALPUR vs. PR.COMMISSIONER OF INCOME TAX-1, JABALPUR

In the result, the assessee‟s appeal is dismissed

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

10,900 and agricultural income of Rs. 1,67,200. Subsequently, it was found by the Revenue that the assessee had during the relevant previous year sold land valued at Rs. 30 lacs or more. Notice u/s. 148 was accordingly issued and served on the assessee on 31/03/2016. The assessee responded by stating that the return filed earlier (on 03/11/2009

INCOME TAX OFFICER, WARD-1, KATNI, KATNI vs. ADITYA AGRAWAL, KATNI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kul Bharatassessment Year: 2016-17 Income Tax Officer, Ward-1 V. Aditya Agrawal Near New Collectorate, Jhinjhiri- C/O. Shri Ram Food 483501. Product, Industrial Area Bargawan-483501. Pan:Amepa0405H (Appellant) (Respondent) Appellant By: Shri Rahul Badia, Ca Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 18 09 2025 Date Of Pronouncement: 30 09 2025 O R D E R

section 10(38) of Income Tax Act, 1961. It has also not been appreciated by the Ld. CIT(A) that the assessee has failed to furnish Form 10DB as required by the Assessing Officer to establish the payment of Security Transaction Tax which would establish the genuinity of the share transaction. 2. Although the tax effect involved in this case

SMT.TEJAL JUGAL KISHORE,SATNA vs. PRINCPAL COMMISSIONER OF INCOME TAX-2, JABALPUR

In the result, the appeal of the assesse is allowed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

section 263 of I.T. Act 1961 for the assessment year under consideration. 4. The order passed by A.O. u/s 143(3) of Income Tax Act 1961 being after proper examination and verification ought to have been held that it is neither erroneous nor prejudicial to the interest of revenue. 2 Tejal Jugal Kishore 3. Heard the arguments of both

SURESH UPADHYAY AND SONS,JABALPUR vs. INCOME TAX OFFICER WARD 2(5),

In the result, the appeals by the assessee‟s are dismissed

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

section to the representative of the postal department, which, as Sh. Mishra indicated, may not be readily available after several years. We think that the assessee, where he intends to press home an „advantage‟ of such nature, ought to have taken steps in time, under RTI Act, seeking specific information in the matter, which the Revenue, a public office

SURESH UPADHYAY AND SONS,JABALPUR vs. INCOME TAX OFFICER WARD 2(5),

In the result, the appeals by the assessee‟s are dismissed

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

section to the representative of the postal department, which, as Sh. Mishra indicated, may not be readily available after several years. We think that the assessee, where he intends to press home an „advantage‟ of such nature, ought to have taken steps in time, under RTI Act, seeking specific information in the matter, which the Revenue, a public office

SURESH UPADHYAY AND SONS,JABALPUR vs. INCOME TAX OFFICER WARD 2(5),

In the result, the appeals by the assessee‟s are dismissed

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

section to the representative of the postal department, which, as Sh. Mishra indicated, may not be readily available after several years. We think that the assessee, where he intends to press home an „advantage‟ of such nature, ought to have taken steps in time, under RTI Act, seeking specific information in the matter, which the Revenue, a public office

SMT. ANURADHA UPADHYAY,JABALPUR vs. INCOME TAX OFFICER WARD 2(5),

In the result, the appeals by the assessee‟s are dismissed

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

section to the representative of the postal department, which, as Sh. Mishra indicated, may not be readily available after several years. We think that the assessee, where he intends to press home an „advantage‟ of such nature, ought to have taken steps in time, under RTI Act, seeking specific information in the matter, which the Revenue, a public office

ANURODH SAHU,JABALPUR vs. ITO (IT AND TP), BHOPAL

In the result, the appeal is allowed for statistical purposes

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

section 148, he declared a total income of Rs. 81,510/-. The assessee submitted that he had purchased Bitcoins during the year from his SBI NRO account as under:- 2 Anurodh Sahu A.Y. 2018-19 Dated Amount (in Rs.) 20.10.2017 100002.38 23.10.2017 400005.90 23.10.2017 300005.90 03.11.2017 100002.36 27.11.2017 100002.36 Total 1000018.90 It was submitted that investment during the said financial

NIKHIL MOHINE,PARASIA vs. COMMISSIONER OF INCOME TAX (APPEALS), JABALPUR

In the result, the assessee’s appeals are allowed

Bench: Sh. Sanjay Arora, Hon'Ble

10 ITA Nos. 37& 38/Jab/2021 (AY 2018-19& 2019-20) Nikhil Mohinev. Dy. CIT/Asst. DIT therein, explain the law as it stands; rather, as it always stood. In fact, that sec. 43B(b) governed only the employer’s contribution, deduction qua which is entitled only on payment by the due date u/s. 36(1)(va), which was later extended

NIKHIL MOHINE,CHHINDWARA vs. DCIT, CPC, BENGULURU

In the result, the assessee’s appeals are allowed

Bench: Sh. Sanjay Arora, Hon'Ble

10 ITA Nos. 37 & 38/Jab/2021 (AY 2018-19 & 2019-20) Nikhil Mohine v. Dy. CIT/Asst. DIT therein, explain the law as it stands; rather, as it always stood. In fact, that sec. 43B(b) governed only the employer’s contribution, deduction qua which is entitled only on payment by the due date u/s. 36(1)(va), which was later extended

M/S RPJ MINERALS PVT. LTD ,MAIHAR vs. INCOME TAX OFFICER, WARD -1,SATNA, SATNA

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

10 ITA No.154/JAB/2016 ITA No.86/JAB/2022 A.Ys. 2012-13 & 2017-18 M/s RPJ Minerals Pvt. Ltd. 50,0000/- have been deposited before the due date of the filing of the return, he gave relief for the same and added back an amount of Rs. 24,91,229/- under section 43B of the Act. 6. Aggrieved with the said addition, the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE KATNI, KATNI vs. J.P TOBACCO PRODUCTS PVT. LTD, DAMOH

In the result, both appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

20,000 raised in previous years from directors and, shareholders were also for business purposes and therefore, payment of interest at the rate of 18% on the brought forward balance of loans was also an allowable deduction under section 36(1)(ii); Consequently, we hold so. 23. We further are of the view that every businessman

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-KATNI, KATNI vs. J.P. TOBACCO PRODUCTS PVT. LTD, DAMOH

In the result, both appeals of the Revenue are dismissed

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

20,000 raised in previous years from directors and, shareholders were also for business purposes and therefore, payment of interest at the rate of 18% on the brought forward balance of loans was also an allowable deduction under section 36(1)(ii); Consequently, we hold so. 23. We further are of the view that every businessman

J.P TOBACO PRODUCTA PVT. LTD.,DAMOH vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - SAGAR, SAGASR

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

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

20,000 raised in previous years from directors and, shareholders were also for business purposes and therefore, payment of interest at the rate of 18% on the brought forward balance of loans was also an allowable deduction under section 36(1)(ii); Consequently, we hold so. 23. We further are of the view that every businessman

J.P TOBACCO PRODUCT PVT. LTD.,DAMOH vs. INCOME TAX OFFICER WARD-3, SAGAR

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

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

20,000 raised in previous years from directors and, shareholders were also for business purposes and therefore, payment of interest at the rate of 18% on the brought forward balance of loans was also an allowable deduction under section 36(1)(ii); Consequently, we hold so. 23. We further are of the view that every businessman

J.P TOBACCO PRODUCT PVT. LTD. vs. DEPUTY COMMISSIONER OF INCOME TAX,,

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

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.

20,000 raised in previous years from directors and, shareholders were also for business purposes and therefore, payment of interest at the rate of 18% on the brought forward balance of loans was also an allowable deduction under section 36(1)(ii); Consequently, we hold so. 23. We further are of the view that every businessman