JAS EQUIPMENTS & ENGINEERS PVT. LTD.,DURGAPUR vs. D.C.I.T., CIRCLE - 2,, DURGAPUR

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. Nos. 519 & 520/Kol/2025 Assessment Year: 2012-2013 Jas Equipments & Engineers Pvt. Limited,…Appellant S-12, Durgapur Industrial Estate, J.P. Avenue, Durgapur-713212, W.B. [Pan:Aabcj9126E] -Vs.- Deputy Commissioner Of Income Tax,..…….Respondent Circle-2, Durgapur, Aayakar Bhawan, City Centre, Durgapur-734101, West Bengal Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Assessee Ms. Ruchika Sharma, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 06, 2025 Date Of Pronouncing The Order: September 30, 2025 O R D E R

TDS on salary payment of Rs.1,58,183/- and reassessed income under section 143(3) read with section 147 at Rs.1

SHREE RAGHUNATH STEEL INDUSTRIES PVT. LTD.,KOLKATA vs. ITO, WD-3(2), KOLKATA, KOLKATA

In the result, both the appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

TDS and charging interest under section 234B and 234C of the Act. Similarly the reassessment for A.Y. 2009-10 was computed

TRIDENT LEATHER ,KOLKATA vs. DCIT, CIRCLE - 54, KOLKATA , KOLKATA

Appeal is allowed

Bench: Sri S.S. Godara) Assessment Year: 2009-10

reassessment. He rather relies upon the assessee’s notings to believe that the payments in question attracted TDS deduction. I quote

I.T.O WD - 2(2),BURDWAN, BURDWAN vs. NATRAJ UNEMPLOYED ENGINEERS CO - OPERATIVE SOCIETY LTD, BURDWAN

In the result, the Cross Objection filed by the assessee is allowed and that of the Revenue is dismissed

Bench: Shri N.V.Vasudevan, J.M. & Dr.A.L.Saini, A.M.)

TDS certificates cannot be a reason good enough to believe that income has escaped assessment and therefore, initiation of reassessment

PATAKA INDUSTRIES PVT. LTD.,KOLKATA vs. ACIT, CIRCLE-8(2), KOLKATA PRESENTLY CIRCLE-7(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11

TDS survey had been ignored and, therefore, led to the reopening of the case of the assessee and the impugned reassessment

GIFFORD & PARTNERS LTD.(SINCE MERGED WITH GIFFORD LLP),KOLKATA vs. DDIT, INTERNATIONAL TAXATION - 1(1), KOLKATA, KOLKATA

In the result ITA No.1489/Kol/11 is partly allowed

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am] Assessment Year : 2007-08

TDS on the payment made by GRSE (i.e. the payer) but did not include the full amount of receipt from GRSE. The treatment given by the assessee in its accounts as well as in computation of its total income was contrary to the provisions of Section 198 & 199 of the Act. In view of this legal position, the difference amount

GIFFORD & PARTNERS LTD.(SINCE MERGED WITH GIFFORD LLP),KOLKATA vs. ADIT (INTERNATIONAL TAXATION) - 1(1), KOLKATA, KOLKATA

In the result ITA No.1489/Kol/11 is partly allowed

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am] Assessment Year : 2007-08

TDS on the payment made by GRSE (i.e. the payer) but did not include the full amount of receipt from GRSE. The treatment given by the assessee in its accounts as well as in computation of its total income was contrary to the provisions of Section 198 & 199 of the Act. In view of this legal position, the difference amount

ITO, WARD-1(4), BURDWAN, BURDWAN vs. SHRI BISHNU GHOSH, BURDWAN

In the result, the appeal of revenue is dismissed

Bench: "ी जे. सुधाकर रे"डी, लेखा सद"य एवं/And "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri J. Sudhakar Reddy, Am & Shri A. T. Varkey, Jm]

reassessment for examining the disallowability of labour charges of Rs.45,76,900/- and job work charges of Rs.23,27,800/- as there was delay in payment of TDS

ACIT, CIRCLE - 4, KOLKATA vs. M/S. APEX ENTERPRISES (I) LTD., KOLKATA

In the result, the appeal of the revenue is dismissed

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

TDS certificate certifying tax deduction of Rs. 11,44,726/- from gross interest of Rs. 54,06,301/- pertaining to Asst Years 1999-2000 to 2002-2003. In the reassessments

DCIT, CC-XXVII, KOLKATA, KOLKATA vs. SRI SATYANARAYAN PANDEY, HOWRAH

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

TDS from the sub-contractor attracts section 40(a)(ia) of the Act and accordingly the whole amount of payment of truck/crane hire charges of Rs.1,56,64,496/- was required to be disallowed and therefore, reassessment

DCIT, CIR-2, ASANSOL, ASANSOL vs. SHRI ATINDRA NATH CHOUBEY, ASANSOL

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

TDS while making payment to all the sub-contractors. The assessee neither obtained Form No.15I from the truck owners nor any declaration in Form 15J was furnished by the assessee. Based on the above reasons, the reassessment

M/S. VICTOR COMMERCIAL CO. LTD.,KOLKATA vs. ACIT, CC - 1(2), KOLKATA, KOLKATA

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

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2010-11 M/S Victor Commercial Co. Acit, Central Circle-1(2), Ltd., Kolkata, C/O. M/S Salarpuria Jajodia & Aayakar Bhawan Poorva, Vs Co., 7, C.R., Avenue, 3Rd Floor, 110, Shantipally, E.M. Kolkata - 700072 Bypass, Kolkata - 700017 (Pan: Aabcv0011C) (Appellant) (Respondent)

reassessment proceedings were completed vide order u/s 147/143(3) wherein certain adjustment/additions/disallowances were made and the income was assessed at Rs.20,35,380/- as against the returned income of Rs. 14,30,900/-. The assessee had claimed credit for TDS

M/S MULTITECH SOLUTIONS,KOLKATA vs. ACIT, CIR. -31, KOLKATA

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

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2013-14

reassessment proceedings. The relationship of the creditors with the partners has also been mentioned and a transaction summary in case of the loan creditors from whom the loan was received by the appellant and later on repaid back with interest after deduction of TDS

SRI KANCHAN KAMAL MUKHOPADHYAY,KOLKATA vs. ITO, WD-20(2), KOLKATA, KOLKATA

In the result both the appeals of the assessee are allowed

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Dr.Arjun Lal Saini, Am] I.T.A Nos. 587 & 588/Kol/2014 Assessment Year : 2008-09 Shri Kanchan Kamal Mukhopadhyay -Vs.- I.T.O., Ward-20(2) Kolkata Kolkata. [Pan : Aanpm 2997 B] (Respondent) (Appellant) For The Appellant : Shri Rip Das, Fca For The Respondent : None Date Of Hearing : 10.07.2017. Date Of Pronouncement : 14.07.2017. Order Per N.V.Vasudevan, Jm

reassessment proceedings the AO noticed that the assessee had not disclosed interest on A.Yr.2008-09 savings bank account to the extent of Rs.2,224.34. The assessee agreed to the action of the AO in bringing to tax the aforesaid interest income after giving credit to TDS

DEEPAK BAJAJ ,KOLKATA vs. ITO, WARD 40(1), KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

TDS namely i) artists remuneration ii)Studio Hire Charges iii)Interest paid on unsecured loans and iv)Car hire charges , conveyance and dep. etc and not in respect of the issues raised by the ld. PCIT in the order passed u/s 263 of the Act. The reassessment

DCIT, CIR-12(2), KOLKATA vs. M/S PHILIPS INDIA LTD., KOLKATA

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

reassessment proceedings u/s 147 of the Act and also the order passed u/s 147/11/254/143(3) of the Act dated 27.12.2017. 3. Facts in brief are that the assessee filed return of income electronically on 12.10.2010 disclosing total income of Rs. 1,76,98,50,492/-. Thereafter the assessee revised the return on 28.03.2012 in which the TDS

M/S PHILIPS INDIA LIMITED (FORMERLY PHILIPS ELECTRONICS INDIA LTD.,KOLKATA vs. A.C.I.T.,CIRCLE-12(2), KOLKATA

In the result, the appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

reassessment proceedings u/s 147 of the Act and also the order passed u/s 147/11/254/143(3) of the Act dated 27.12.2017. 3. Facts in brief are that the assessee filed return of income electronically on 12.10.2010 disclosing total income of Rs. 1,76,98,50,492/-. Thereafter the assessee revised the return on 28.03.2012 in which the TDS

DCIT, CENTRAL CIRCLE - 4(4), KOLKATA, KOLKATA vs. M/S. EVERNEWCOMMODEAL PVT. LTD. , KOLKATA

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

reassessment proceedings. The ld. AR further submits that the assessee has given complete chart regarding the loan taken from the parties such as PAN cards of the parties and their regular filer of Income Tax details. The ld. AR further submits that the assessee had duly paid interest of the loans and offered the same after deducting TDS