DEPUTY COMMISSIONER OF INCOME TAX(CENTRAL), JABALPUR vs. ANAND MINING CORPORATION, JABALPUR

In the result, the Cross Objection of the assessee is partly allowed

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

10 Assessment Year:2014-15 Firm was not paying any payment to partner for the food grains cultivated and used by the assessee firm in its mess. The agriculture expenses were also debited in the mess expenses. Since the assessee Firm had used in its mess the food-grains produced in the agriculture land, the disallowance has been deleted

SANJAY KUMAR AGRAWAL ,SATNA vs. ASST. COMMISSIONER OF INCOMETAX CIRCLE, SATNA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Sanjay Kumar Agarwal V. Acit Circle Satna Blooms Campus, Nh-75, Panna Aayakar Bhawan, Civil Road, Satna (Mp)-485001. Lines, Satna, Mp-485001. Tan/Pan:Ackpa2596H (Appellant) (Respondent) Appellant By: Shri Sanjay Mishra, Adv Respondent By: Shri N. M. Prasad, Sr. Dr-1 Date Of Hearing: 19 08 2025 Date Of Pronouncement: 21 08 2025 O R D E R

20,00,000/- are genuine and borrowed for the purpose of business, Ld CIT (A) erred in disallowing interest Rs. 1,93,050/- paid thereon. 8 Considering the fact that interest Rs. 10,286/- paid by the assessee on the late deposit of TDS is compensatory in nature and its disallowance is not provided, in income tax act specifically

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-KATNI, KATNI vs. M/S. GAJRAJ MINING PVT. L:TD., SINGRAULI

In the result, the appeal of the Revenue as well as assessee is dismissed

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

20,00,000/- and added back to the income of the appellant holding that these expenses are not verifiable. The ld. CIT(A) restricted the addition to Rs. 2,00,000/- on adhoc basis. Since the disallowance by the AO and the restriction of disallowance by the CIT(A) on adhoc basis, in the absence of any evidence of bogus

ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-CHHINDWARA, CHHINDWARA vs. SHRI SHEVENDRA SINGH PARIHAR, BALAGHAT

In the result, the appeal of the Revenue is dismissed

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

disallowance was restricted by the learned CIT(A) @10% out of the expenditure pertaining to mine development and sub-contract. The said approach of CIT(A) is found to be reasonable which requires no interference at the hands of this Tribunal as the Department has not pointed out any defect in the books of account. Accordingly, ground

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL) , JABALPUR vs. M/S. JABALPUR HOSPITAL & RESEARCH CENTER, JABALPUR

In the result, the appeal filed by the revenue is dismissed and the Cross objections filed by the assessee are partly allowed

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaledcit, Vs. Jabalpur Hospital & Central Circle, Researchcentre,Pvtltd Ramnath Russel Crossing, Building,Napier Town, Napier Town, Jabalpur-482001, Jabalpur-482001 Madhya Pradesh. Madhya Pradesh Pan/Gir No. : Aabcj1959K Appellant .. Respondent Co.No.04/Jab/2019 (A.Y. 2016-17) (In Ita No.19/Jab/2019) Jabalpur Hospital & Vs. Dcit, Research Centre Pvt Ltd, Central Circle, Russel Crossing, Ramnath Napier Town, Building,Napier Town, Jabalpur-482001. Jabalpur-482001. Madhya Pradesh. Madhya Pradesh. Pan/Gir No. : Aabcj1959K Appellant .. Respondent

10,40,000/-. 4.(v) the A.O on perusal of the seized documents page 3 LPS-2 containing the details of transaction of Rs. 1,93,19,791/-, being interest free loans provided to Global Foundation and Medical Education and at the same time, the assessee is claiming huge expenditure on account of financial charges. The AO has dealt

INCOME TAX OFFICER, WARD-1, CHHINDWARA vs. SHRI SIDDHIVINAYAK EDUCATION SOCIETY, CHHINDWARA

In the result, the appeal of the Revenue is hereby dismissed

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

section 57 of Rs. 2,46,00,672/- out of total receipt of Rs. 2,46,48,97 2/-. 10. The assessee is imparting training as per NSDC norms. For imparting the training, the appellant have to incur the expenditure. The appellant is maintaining books of accounts. It was held that the AO has not pointed out any defect

J.P TOBACCO PRODUCT PVT. LTD.,DAMOH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE, SAGAR

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalem/S. J.P.Tobacco Products Vs Acit, Pvt. Ltd., Patharia Phatak, Circle-Sagar. Damoh (M.P.). (Appellant) (Respondent) Pan No. Aaacj7141G Assessee By Shri G.N.Purohit, Sr.Adv. & Shri Abhijeet Shrivastava, Adv. Revenue By Shri Rajesh Kumar Gupta, Sr.Dr Date Of Hearing 15/09/2023 Date Of Pronouncement 22/09/2023

disallowance of the interest. The Tribunal held that if there could be two views about the claims of the assessee, the explanation offered by it cannot be said to be false. The penalty was accordingly deleted by the Tribunal. The order of the Tribunal was maintained by the High Court. It was contended on behalf of the Revenue, before

VISHAL DATT,JABALPUR vs. ACIT CIRCLE 2(1) , JABALPUR

In the result, appeals of the assessee are allowed for\nstatistical purposes

20,66,976/- as 'leveling charges to\nP/L account. Assessee had done leveling work through contractor and TDS\nhad been deducted on payment. In case of labour charges there are very\nfew instances where receiver signature were not found due-to the reason\nthat the amount was collected by the mukaddam i.e. head of the group of\nlabourer same 'were

JILA SAHKARI KENDRIYA BANK KARAMCHARI SAKH SAHKARI SAMITI,SATNA vs. ASSISTANT COMMISSIONER OF INCOMETAX, KATNI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalejila Sahkari Kendriya Bank Vs National E Karamchari Sakh Sahkari Assessment Samiti Maryadit Satna, Center, Income Tax Sahkar Bhawan, Behind Department, New Green Talkies, Pushpraj Delhi Colony, Satna (M.P)-485001. Acit, Katni (Appellant) (Respondent) Pan No. Aabaj4497Q Assessee By None Revenue By Shri Shiv Kumar, Sr.Dr Date Of Hearing 12/09/2023 Date Of Pronouncement 20/09/2023

20(2)(2), Mumbai (ITA NO. 6139/Mum/2014, dated 27.09.2017. (v). Kaliandas Udyog Bhavan Premises 8 | P a g e Co-op. Society Ltd. Vs. ITO, 21(2)(1), Mumbai. In the aforesaid orders, it has been held by the Tribunal that though the cooperative banks pursuant to the insertion of sub-section (4) to Sec. 80P of the Act would

M/S NARSINGH EXTRACTION & ALLIED PRODUCTS P. LTD,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), JABALPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalem/S. Narsingh Extraction & Vs Asst.Cit, Allied Products P.Ltd., Circle-2(1), 389, Gupteshwar Ward, Jabalpur Madan Mahal, Jabalpur. (Appellant) (Respondent) Pan No. Aabcn2387H Assessee By Shri Neeraj Agrawal, Ca Revenue By Shri Saad Kidwai, Cit Dr Date Of Hearing 20/09/2023 Date Of Pronouncement 22/09/2023

section 43B of the Act. 6. That on the facts and in the circumstances of the case the Id AO was not justified in disallowing Rs. 80,000/- out of packing material expense and Rs. 20,000/- out of refinery chemical expense on conjecture and surmises. 7. That considering the fact that poojan expense of Rs. 96,045/- incurred

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

10 CTR 0375 (SC), in which it is decided that interest expenditure on borrowings is not allowed if the same is not related to the business of the assessee. The amount of Rs. 11,59,23,319/- on account of interest on borrowed fund is not eligible for disallowance u/s 37(1) of the IT Act. As the borrowed fund

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

10 CTR 0375 (SC), in which it is decided that interest expenditure on borrowings is not allowed if the same is not related to the business of the assessee. The amount of Rs. 11,59,23,319/- on account of interest on borrowed fund is not eligible for disallowance u/s 37(1) of the IT Act. As the borrowed fund

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-SATNA, SATNA vs. M/S. RAM KUMAR SURESH KUMAR, SATNA

In the result, the appeal filed by the Revenue is allowed

Bench: Shri Om Prakash Kantshri Pavan Kumar Gaaleasst. Commissioner Of Vs Shri Ram Kumar Income Tax, Circle-Satna, Suresh Kumar, Satna Birla Road, Satna (Appellant) (Respondent) Pan No. Aaffr3899D Revenue By Shri Shravan Kumar Gotru, Cit Dr Assessee By Shri Rahul Bardia, Fca Date Of Hearing 13/09/2023 Date Of Pronouncement 22/09/2023 O R D E R Per Om Prakash Kant, A.M.: This Appeal By The Revenue Is Directed Against Order Dated 12.03.2018 Passed By Ld. Commissioner Of Income Tax(Appeals)-1, Jabalpur [In Short “Ld.Cit(A)”] For The Assessment Year 2013-14, Raising Following Grounds:

disallowed expenditure claimed. Tribunal held that though purchases were from bogus parties, nevertheless purchases themselves were not bogus, so not the entire amount, but profit margin embedded in such amount only would be subjected to tax. The High Court held, whether purchases themselves were bogus or whether parties from whom such purchases were allegedly made were bogus is essentially

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.

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

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.

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

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.

disallowance following the binding precedents in the case of the assessee itself. For ready-reference, the finding of Tribunal in the case of the assessee in ITA I.T.A. No.263/Jab/2016 Assessment Year:2012-13 3 No217/Jab/2015 and others for AY 2007-08 and others dated 27.04.2018 is reproduced as under:- 18. “We have heard the rival contentions and perused the record

KOHINOOR TOBACCO PRODUCTS PRIVATE LIMITED JABALPUR,JABALPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, JABALPUR, JABALPUR

In the result, the appeal is dismissed as withdrawn

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.-2018-19 Kohinoor Tobacco Products Private Vs. Pr. Commissioner Of Income Limited, 903, M.H. House, Gole Bazar, Tax, Jabalpur-1 Jabalpur, M.P. Pan:Aabck7797E (Appellant) (Respondent)

20-09-2021 despite there being complete application of mind by the AO on the subjected issues being the loans received and squared up was duly verified by the AO, it was nothing but a case of change of opinion, based on which, assumption of jurisdiction u/s 263 is not permissible. The impugned order dated 29-02-2024, therefore, lacks