BRAHTAKAR KRISHI SAKH SAHAKARI SAMITI MARYADIT,SAHAJPUR vs. INCOME TAX OFFICER WARD 1(2), JABALPUR

In the result, all the three appeals in ITA Nos

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

disallowance in the year under consideration is bad in law. ADDITIONAL GROUND 5. The AO was not justified in passing order under section 147 of the Act without issuing any notice under section 148 as the notice issued under section 148 was not issued to anybody as apparent from the portal. 6. The AO was not justified in passing order

RAI SAHAB BHAIYALAL DUBEY EDUCATIONAL AND MEDICAL CHARITABLE TRUST,JABALPUR vs. INCOME TAX OFFICER (EXEMPTION), JABALPUR

In the result, the appeal is partly allowed for statistical purposes

Bench: Shri Anadee Nath Misshra

7. In the light of the above, let us consider the scope of section 154 for making prima facie adjustment while processing return under section 143(1)(a) of the Act i.e. process of dealing with the return is an ex parte process. It is pertinent to observe that whenever any debatable issue is involved an explanation of the assessee

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

disallowed by Assessing Officer & 7 | P a g e confirmed by the Ld.CIT(A) by relying upon decision rendered by Hon’ble Karnataka High Court in case of principle Ld.CIT Vs. Totgar’s Co-Operative Sales Society Ltd. 7. Issue as to the allow-ability of the deduction claimed by the Assessee

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE SAGAR, SAGAR vs. SHRI RISHAV KUMAR JAIN, SAGAR

In the result, the appeal of the Revenue is partly allowed

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

7. The assessee produced some vouchers regarding the expenses. However, the Assessing Officer accepted the vouchers of bank commission and rejected other expenses. Learned CIT(A) while restricting the addition held as under: “i. Labour Expenses The labour register was produced before the Assessing Officer and no adverse comment was made except one entry which is a typographical error

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

7 CO No. 05/ JAB/2020 Gajraj Mining P Ltd. of this section, shall be allowed if such interest has been actually paid and any interest referred to in that clause which has been converted into a loan or advance shall not be deemed to have been actually paid. Explanation 4.— For the purposes of this section, — (a) "public financial institutions

KHANNA AUTOMOBILES REWA,REWA vs. INCOME TAX OFFICER, REWA

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

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2014-15 Khanna Automobiles V. Income Tax Officer 01 M/S Khanna Automobile, Ward-1 Bus Stand, Rewa, Madhya Income Tax Office, Kothi Pradesh-486001. Compound, Behind Customer Forum, Rewa- 486001. Pan:Aahfk4140J (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Adv. Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 20 05 2025 Date Of Pronouncement: 30 06 2025 O R D E R

7. The order passed under section 143(3) r.w.s 147 is bad in law as the reopening of assessment was without any new information and no tangible material was gathered by the AO and reason was based on the basis of available record and it appears that it was on the basis of audit objection and it is settled position

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

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

7,80,732. During the assessment\nproceedings details required by AO were submitted. It is submitted that if\nthe A as disallowed 10 percent lump-sum of salary by stating that the\nexpenses are not explained properly. Addition made by AO is not correct\nand the same may kindly be deleted. Against the order passed assessee\nmade an appeal before

INCOME TAX OFFICER WARD-1, CHHINDWARA vs. M. P. RASTRIYA KOYLA KHADAN MAJDOOR SANGH COLLIERY EMPLOYEE COOPERATIVE SOCIETY, CHHINDWARA

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

disallowance, since deleted in first appeal by the Commissioner of Income Tax (Appeals)-1, Jabalpur (‗CIT(A)‘, for short) vide his order dated 08/07/2020 in respect of the assessee‘s assessment under section 143(3) of the Income Tax Act, 1961 (‗the Act‘ hereinafter), dated 12/12/2019 for the Assessment Year (AY) 2017-18. 2. The appeal raises the following grounds

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

disallowance, but\nhad no objection to the matter being sent back for verification of facts.\n9. We have duly considered the facts and circumstances of the case and the\norders of the lower authorities. We have also had occasion to go through the orders\ncited by the lower authorities while rendering their decision and before we\nadjudicate on the issue

RASHMEET SINGH MALHOTRA vs. INCOME TAX OFFICER WARD-1,

In the result, the appeal of the assesse is allowed

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

Section 48 of the I.T Act. Adhoc disallowance: 6. The AO has observed that assessee has claimed shop expenses, telephone expenses, mobile expenses, travelling and conveyance expenses, generator expenses and repair and maintenance expenses. A.O. has made adhoc addition of Rs.50,000/- by observing that the personal element in above said expenses cannot be ruled out. Assessee has maintained regular

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 12A of the Income Tax Act, 1961 and engaged in providing skill training courses to students. The 2 Shri Sidhivinayak Education Society the assessee filed return of income declaring an amount of Rs. 48,300/-. As the society could not establish the genuineness/ veracity of the claim of expenditure the Aessing Officer disallowed the entire amount of expenditure. Rs.2

RAMJIDAS BUDHRAJA CHARITABLE TRUST (SGM),CHHINDWARA vs. INCOME TAX OFFICER EXEMPTION, JABALPUR

In the result, the appeal of the assessee is dismissed

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

7 assessee and, therefore, the benefit of Section 11 could not have been denied. In this background of facts the ground wise submission in appeal is as under:- A. In the first ground of appeal the assessee has challenged the validity of notice under Section 148 firstly on the ground that learned Assessing Officer in the assessment order has mentioned

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

7 Since loans received Rs. 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

SMT HANSA SHAH,JABALPUR vs. DCIT CIRCLE 2(1) JABALPUR, JABALPUR

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

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

disallowance to this extent and initiated the penalty proceedings. 3. Aggrieved with the same, the assessee filed an appeal with the ld. CIT(A)-2, Bhopal which was subsequently migrated to the e-Appeal Scheme 2023. The ld. Addl/JCIT(A) notes that following the same, three notices of hearing were issued to the assessee

GAURAV SINGH,SATNA vs. ITO-WARD SATNA, SATNA

In the result, the appeal is allowed

Bench: Shri Om Prakash Kant& Shri Pavan Kumar Gadalegaurav Singh, Ito, C/0,Rajiv Narayan Singh, Aayakar Bhawan, Parijat Niwas, Civil Lines, Satna-485001. Satna-485001. Madhya Pradesh, Madhya Pradesh, Appellant Respondent Pan: Bbdps8879Q

7. We find under Section 90 of the income tax Act allows double taxation relief in respect of agreements with foreign countries or specified territories and also Section 91 o the I T Act deals with the taxability of income where the countries which don’t have agreements. Further there is no amendment in the Section

ULTRA CLEAN AND CARE SERVICES P LTD. ,JABALPUR vs. ASSTT. COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR, JABALPUR

In the result, both appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

section 43B and conflicting and ambiguous. The conflict should be resolved in favor of the assessee. 2 | P a g e ITA Nos.8 & 9/Jab/2023 Ultra Clean and care Ser vices P.Ltd. 6. The applicant reserves his right to raise additional ground or grounds of appeal those may arise at the time of hearing of this appeal.” 3. Grounds raised

ULTRA CLEAN AND CARE SERVICES P LTD. ,JABALPUR vs. ASSTT. COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR, JABALPUR

In the result, both appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

section 43B and conflicting and ambiguous. The conflict should be resolved in favor of the assessee. 2 | P a g e ITA Nos.8 & 9/Jab/2023 Ultra Clean and care Ser vices P.Ltd. 6. The applicant reserves his right to raise additional ground or grounds of appeal those may arise at the time of hearing of this appeal.” 3. Grounds raised

SHRI GOVIND SINGH, REWA vs. INCOME TAX OFFICER,WARD-1,, SATNA

In the result, the appeal of the assesse is dismissed

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

7. The A.O. erred in disallowing Rs. 10,670/ - in respect to fee on alc of delay in filing of GST return; failing to appreciate tha t the fee paid for delay in filing of GST return is an allowable expenditure. 2. The issue of ESI/PF payment has attained finality by the order of the Hon’ble Supreme Court