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

c) "State industrial investment corporation" means a Government company within the meaning of section 617 of the Companies Act, 1956 (1 of 1956), engaged in the business of providing long -term finance for industrial projects and eligible for deduction under clause (viii) of sub-section (1) of section 36; 54[(d) "co-operative bank", "primary agricultural credit

VICKY NAVANI,JABALPUR vs. INCOME TAX OFFICER, WARD 1(3), JABALPUR, WARD )), JABALPUR

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

Bench: Shri Anadee Nath Misshra

6. Audit report was uploaded on 31/03/2017 therefore the limitation starts from 01/04/2017 for initiation of penalty and penalty could be imposed before the expiry of 31/03/2018. Hence, the penalty proceedings so initiated on 01/03/2019 is barred by limitation in view of the provisions of section 275 of the IT Act, 1961. The rebuttal by the Ld.JAO

NAGAR PANCHAYAT,BANDA vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX CIRCLE SAGAR, SAGAR

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2012-13 Nagar Panchayat, Banda, Vs. The Acit, Nagar Parishad Building, Banda, Sagar, Circle Sagar, Sagar Banda Nagar S.O. Madhya Pradesh Pan:Aaaln0246R (Appellant) (Respondent) Assessee By: Sh. Milind Wadhwani, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 19.05.2025 Date Of Pronouncement: 30.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 7.05.2024 Whereby The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Of The Dcit, Circle-Sagar, Madhya Pradesh Passed On 10.12.2019 Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. On The Facts & Circumstances Of The Case & In Law, The Ld. National Faceless Appeal Centre ('Nfac) Erred In Upholding The Action Of The Ld. Assistant Commissioner Of Income Tax Circle-Sagar ('Ao) In Adding A Sum Of Rs. 68,21,182/- To The Income Of The Assessee U/S. 69A As Unexplained Money. 2. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 10.12.2019 Is Without Jurisdiction, Bad In Law & Liable To Be Quashed.3 3. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Is Opposed To The Principles Of Equity, Natural Justice & Fair Play.

68,21,182/- to the income of the assessee u/s. 69A as unexplained money. 2. On the facts and circumstances of the case and in law, the assessment order dated 10.12.2019 is without jurisdiction, bad in law and liable to be quashed.3 3. On the facts and circumstances of the case and in law, the assessment order is opposed

JAINAM GROUP CHHINDWARA,CHHINDWARA vs. COMMISSIONER OF INCOME-TAX (APPEALS), NATIONAL FACELESS APPEAL CENTRE (NFAC) DELHI

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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

c) and 271(1)(b) of the Act. 3. Aggrieved with the said additions, the assessee went in appeal before the ld. CIT(A), NFAC. The ld. CIT(A), NFAC observed that the appeal, which was to be filed by 25.03.2022, had only been filed on 8.08.2022 i.e. it was not on time. He further noted that the assessee

DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1), JABALPUR vs. SHRI INDRABHAN SINGH RATHORE, NARSINGHPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

section 68 of the Income Tax Act, 1961. Furthermore, it was submitted that these amounts had been reflected as unsecured loans in the income tax returns of the assessee and therefore, they were well within the scope of scrutiny. 6. On the other hand, Sh. Sapan Usrethe, Adv (hereinafter referred to as the ‘ld. AR’) appearing on behalf

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

68 of the Income Tax Act, 1961, despite the Appellant having availed the VSVS scheme. 11.That the learned CIT(A) erred in upholding the rejection of the Appellant’s claim of exemption under section 10(38) of the Income Tax Act, 1961, despite the Appellant having availed the VSVS scheme. 12.That the learned CIT(A) order is passed without

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:

section 68 is not sustainable. We therefore delete the same and allow ground No.3 of assessee's appeal. 16 | P a g e ACIT vs Shri Ram Kumar Suresh Kumar (vii) In the case of Megha S. Shah v DCIT [2013] 38 CCH 76 the hon'ble ITAT Ahemdabad 'C' Bench has held as under :- "11. We have heard

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL), JABALPUR vs. M/S SHOBHA MINERALS (DHAMKI), JABALPUR

In the result, appeals of the assessees are allowed and the Revenue’s appeals are dismissed

Bench: Shri Bhavnesh Saini & Shri Sanjay Aroraassessment Year:2015-16 M/S. Shobha Minerals (Kevlari) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abifs 4245A] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Kevlari) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abifs 4245A] (Appellant) (Respondent) Assessment Year:2015-16 M/S. Shobha Minerals (Dhamki) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abmfs5899N] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Dhamki) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abmfs 5899N] (Appellant) (Respondent)

6 (i.e., 85% of 1,92,400 MT), considering which the iron ore stock works to 2,08,862.655 MT (i.e., 45,322.655 MT + 1,63,540 MT). There was, accordingly, an excess book-stock of 73,181.055 MT (i.e., 2,08,862.655 – 1,35,681.600), or 36,400.34 MT (if the iron ore component

M/S SHOBHA MINERALS (KEVLARI),JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE, JABALPUR

In the result, appeals of the assessees are allowed and the Revenue’s appeals are dismissed

Bench: Shri Bhavnesh Saini & Shri Sanjay Aroraassessment Year:2015-16 M/S. Shobha Minerals (Kevlari) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abifs 4245A] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Kevlari) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abifs 4245A] (Appellant) (Respondent) Assessment Year:2015-16 M/S. Shobha Minerals (Dhamki) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abmfs5899N] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Dhamki) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abmfs 5899N] (Appellant) (Respondent)

6 (i.e., 85% of 1,92,400 MT), considering which the iron ore stock works to 2,08,862.655 MT (i.e., 45,322.655 MT + 1,63,540 MT). There was, accordingly, an excess book-stock of 73,181.055 MT (i.e., 2,08,862.655 – 1,35,681.600), or 36,400.34 MT (if the iron ore component

M/S SHOBHA MINERALS (DHAMKI),JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE, JABALPUR

In the result, appeals of the assessees are allowed and the Revenue’s appeals are dismissed

Bench: Shri Bhavnesh Saini & Shri Sanjay Aroraassessment Year:2015-16 M/S. Shobha Minerals (Kevlari) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abifs 4245A] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Kevlari) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abifs 4245A] (Appellant) (Respondent) Assessment Year:2015-16 M/S. Shobha Minerals (Dhamki) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abmfs5899N] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Dhamki) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abmfs 5899N] (Appellant) (Respondent)

6 (i.e., 85% of 1,92,400 MT), considering which the iron ore stock works to 2,08,862.655 MT (i.e., 45,322.655 MT + 1,63,540 MT). There was, accordingly, an excess book-stock of 73,181.055 MT (i.e., 2,08,862.655 – 1,35,681.600), or 36,400.34 MT (if the iron ore component

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL), JABALPUR vs. M/S SHOBHA MINERALS (KEVLARI), JABALPUR

In the result, appeals of the assessees are allowed and the Revenue’s appeals are dismissed

Bench: Shri Bhavnesh Saini & Shri Sanjay Aroraassessment Year:2015-16 M/S. Shobha Minerals (Kevlari) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abifs 4245A] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Kevlari) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abifs 4245A] (Appellant) (Respondent) Assessment Year:2015-16 M/S. Shobha Minerals (Dhamki) Vs. Asst. Cit, 765 Near Anand Talkies, Central Circle, Napier Town, Jabalpur Jabalpur [Pan: Abmfs5899N] Assessment Year:2015-16 Asst. Cit(Central), Vs. M/S. Shobha Minerals (Dhamki) Jabalpur 765 Near Anand Talkies, Napier Town, Jabalpur [Pan: Abmfs 5899N] (Appellant) (Respondent)

6 (i.e., 85% of 1,92,400 MT), considering which the iron ore stock works to 2,08,862.655 MT (i.e., 45,322.655 MT + 1,63,540 MT). There was, accordingly, an excess book-stock of 73,181.055 MT (i.e., 2,08,862.655 – 1,35,681.600), or 36,400.34 MT (if the iron ore component

BASANT GROVER,JABALPUR vs. INCOME TAX OFFICER WARD 2(3), JABALPUR

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

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalebasant Grover, Vs Ito, 245/2, Behind Ashoka Ward-2(3), Apartment, Madanmahal, Jabalpur. Jabalpur-482002 (M.P.) (Appellant) (Respondent) Pan No. Adbpg3734F Assessee By None Revenue By Shri Rajesh Kumar Gupta, Sr.Dr Date Of Hearing 13/09/2023 Date Of Pronouncement 20/09/2023

section 250 of the Income Tax Act, 1961 is illegal and bad in law being ex-parte, thus violating the "principle of natural justice", by not giving proper opportunity to the assessee; who was bedridden due to heart problem and 1 | P a g e was thus prevented in giving replies to the notices which is a reasonable cause

MADHYA PRADESH POORVE KESHTRA VIDYUT VITRAN CO.LTD.,JABALPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR

In the result, the assessee’s appeal is dismissed

Bench: Shri Bhavnesh Saini & Shri Sanjay Aroraassessment Year: 2008-09 Madhya Pradesh Poorv Kshetra Vs. Assistant Commissioner Of Vidyut Vitran Co. Ltd., Income Tax, Jabalpur Circle 2(1), [Pan: Aadcm 6175E] Jabalpur (Appellant) (Respondent) Appellant By Shri Sukesh Kumar, Ca Respondent By Shri I.B. Khandel, Senior Dr Date Of Hearing 11/12/2019 Date Of Pronouncement 20/01/2020

68,642. The assessee’s stand is that the same is a perquisite in the hands of the employees, forming part of their salary income and, therefore, excluded under FBT (s.115WB(3)). Tax on the said perquisite, however, had not been deducted at source as its’ employees had contested the same before the Hon’ble High Court, which matter

SHRI MANOJ KUMAR BAN SHYAM BAND,JABALPUR vs. INCOME TAX OFFICER, JABALPUR

Bench: Shri Kul Bharat & Shri Manish Borad""./ Ita Nos. 98 & 99/Jab/2013 "" " " " " " "  / Assessment Year : 2007-08   Shri Manoj Kumar Ben, Income Tax Officer, Shri Shyam Band, Near Vs Ward 1 (1), Lordganj Thana, Jabalpur Jabalpur Pan : Agopb 2241 C / (Appellant) / (Respondent)         Assessee By : Sh. M.M. Nema, Adv. Revenue By : Sh. P.D. Chougule, Dr $ %&'/Date Of Hearing : 12/03/2018 ! "# $ %&' /Date Of Pronouncement: 14/03/2018 ()*+ "# .//O R D E R , - Per Kul Bharat:-

1)(c), are directed against the order of ld. CIT(A) dated 23.07.2012 and 24.07.2012 respectively for Assessment Year 2007-08. Since the issue involved in these appeals is common, both these appeals were heard together and are being disposed of by this consolidated order for the sake of convenience. 2. First we take up ITA No.98/Jab/2013 pertaining to Assessment

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1), JABALPUR vs. CHETANAYA PROMOTERS AND DEVLOPERS,, JABALPUR

In the result, on this ground, appeal of the Revenue as well as appeal of the assessee is hereby dismissed

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

C-2(1), Jabalpur, MP Developers, s 353, Swarn Bhoomi, Chaggar Farm, Bilhari, Jabalpur, MP (APPELLANT) (RESPONDENT) PAN No. AAHFC 0135 H Assessee by : Sh. Dhiraj Ghai, FCA Revenue by : Smt. Garima Chaudhary, CIT-DR Date of Hearing: 22.11.2023 Date of Pronouncement: 23.11.2023 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeals have been filed by Revenue

SHRI NITIN SHARMA,JABALPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX -2, JABALPUR

In the result, the appeal is partly allowed

Bench: Shri N.R.S. Ganesan & Shri Sanjay Arora

C. Parakh & Co. (India) Ltd. [1956] 29 ITR 661 (SC); Kedarnath Jute Mfg. Co. Ltd. v. CIT [1971] 82 ITR 363 (SC)). A ‘mistake’, in any case, cannot give rise to any right to the other side. Any surviving doubt in the matter would stand quenched with reference to s. 292B. 4.2 Continuing further, as we see it, the assessment

M/S.ASIT DIXIT,JABALPUR vs. INCOME TAX OFFICER WARD2(2), JABALPUR

In the result, the assessee’s appeal is partly allowed for statistical purposes

Bench: Sh. Sanjay Arora, Hon'Bleassessment Year : 2005-06 Asit Dixit, Income Tax Officer, Vs. Ward-2(2), Jabalpur (M.P.) Jabalpur [Pan: Aanfm 5798A] (Appellant) (Respondent) Appellant By Sh. Sanjay Seth, Ca Respondent By Sh. S.K. Halder, Sr. Dr Date Of Hearing 16/09/2021 Date Of Pronouncement 07/10/2021

section 144 of the Income Tax Act, 1961 (‘the Act’ hereinafter) for the Assessment Year (AY) 2005-06 vide Order dated 24/11/2010. 2. The appeal raises two grounds, as under, which shall be taken up in seriatim: ‘1. That the assessee had filed ITR declaring loss of Rs. 26,130 and the AO has estimated profit at Rs. 6

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

68,087/- was not reflected into Page 3 of 5 profit & loss account (b) The assessee firm made investment of Rs.25,00,000/- which would fetch exempt income and no disallowance as per Rule 8D of Income Tax Rules, 1962 (“Rules”, for short) was made by the assessee and (c) It was noticed that total investment into the shares