PAIRAGACHA COOPERATIVE CREDIT SOCIETY LIMITED,PAIRAGACHA vs. ITO, HOOGHLY

In the result, both the appeals of the assessee are allowed

Bench: Shri Sanjay Garg & Shri Girish Agrawal

272A(1)(d) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”) and against the assessment order by ITO, Ward-23(1), Hooghly dated 22.11.2016 u/s.143(3) of the Act for AY 2019-20 respectively. 2. Both the appeals are time barred by 14 days. In respect of AY 2018-19 the assessee has filed an affidavit

HARIKISHAN DASS RAMKISHAN,KOLKATA vs. I.T.O WD - 45(4),KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed as stated above

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

disallowance of interest expenditure u/s. 40(a)(ia) r.w.s 194A of the Act and notice was issued to the assessee. In response to such notice the assessee submitted that the loan creditors has deposited their Form No.15G/15H requesting the assessee not to deduct TDS at source on such amount. Besides, the assessee also submitted that it is not conversant with

SRI SIBENDU BASU,KOLKATA vs. DCIT,CIR.-54, KOLKATA, KOLKATA

In the result, the appeal of the assessee is dismissed

Bench: Hon’Ble Shri P.M. Jagtap] I.T.A. No. 315/Kol/2017 Assessment Year : 2006-07 Shri Sibendu Basu.............................………………………………………….............Appellant 39A, Townshend Road, Ground Floor, Kolkata – 700 025 [Pan : Aecpb 9682 F] D.C.I.T. Cir-54 Kolkata...................……………………………………………….......Respondent 54/1, Rafi Ahmed Kidwai Road, Kolkata – 700 016 Appearances By: Shri Subash Agarwal, Advocate Appearing On Behalf Of The Assessee. Shri Satyajit Mondal, Addl. Cit Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : October 31, 2017 Date Of Pronouncing The Order : December 22, 2017 Order This Appeal Filed By The Assessee Is Directed Against The Order Of Ld. Cit (Appeals) – 21, Kolkata Dated 03.01.2017. 2. The Issue Involved In Ground No 1 Relates To The Addition Of Rs. 5,34,700/- Made By The A.O. & Confirmed By The Ld. Cit(A) On Account Of Disallowance Of Fund Mobilisation Expenses. 3. The Assessee In The Present Case Is An Individual Who Derives Income From Legal Profession, Commission & Brokerage From Insurance & Mutual Funds Companies, Long Term & Short Term Capital Gains Etc. The Return Of Income For The Year Under Consideration Was Filed By Him 30.10.2006 Declaring A Total Income Of Rs. 2,66,160/-. In The Profit & Loss Account Filed Along With The Said

section 272A of the Income Tax Act, 1961, as well as per Rule 12 of Order XVI of the Civil Procedure Code” 5. The Ld. CIT(A) did not find merit in the submissions made by the assessee and proceeded to confirm the disallowance

BISWANATH AGARWALA,KOLKATA vs. ACIT, CIRCLE - 43, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: "ी ऐ. ट". वक", "यायीक सद"य) [Before Shri A. T. Varkey, Jm] I.T.A. No. 1843/Kol/2018 Assessment Year: 2013-14

disallowance was ordered for non-deduction of TDS. We note that a similar issue was considered by the Coordinate Bench of this tribunal Bombay Bench in the case of Karwat Steel Traders Vs. ITO, ITA No. 6822/Mum/2011 for AY 2008- 09 dated 10.07.2013 wherein a similar issue arose and the Tribunal held as under: “4. We have considered the issue

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

272A(1)(d) of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since the issues involved in all the appeals are interconnected and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this common order. ITA Nos.2066 to 2071/Kol/2025 Ishtiyaque Ahmed 2. ITA No.2066/Kol/2025 - Facts in brief

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3), KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

272A(1)(d) of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since the issues involved in all the appeals are interconnected and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this common order. ITA Nos.2066 to 2071/Kol/2025 Ishtiyaque Ahmed 2. ITA No.2066/Kol/2025 - Facts in brief

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC - 4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

272A(1)(d) of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since the issues involved in all the appeals are interconnected and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this common order. ITA Nos.2066 to 2071/Kol/2025 Ishtiyaque Ahmed 2. ITA No.2066/Kol/2025 - Facts in brief

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

272A(1)(d) of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since the issues involved in all the appeals are interconnected and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this common order. ITA Nos.2066 to 2071/Kol/2025 Ishtiyaque Ahmed 2. ITA No.2066/Kol/2025 - Facts in brief

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2066 To 2071/Kol/2025 Assessment Years: 2020-21, 2021-22, 2022-23, 2019-20, 2020-21 & 2022-23 Ishtiyaque Ahmed……...……………..………………….……….……….……Appellant 55, Narkeldanga North Road, Narkeldanga, Kol-11.. [Pan: Ajxpa4337L] Vs. Dcit/Acit, Cc-4(3), Kolkata.……….…………………….....……...…..…..Respondent Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Subrata Aich, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 10, 2025 Date Of Pronouncing The Order : December 08, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The “Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”]. Ita Nos.2066 To 2068/Kol/2025 Are Pertaining To The Quantum Additions & Ita Nos.2069 To 2071/Kol/2025 Are Pertaining To Levying Of Penalty U/S 272A(1)(D) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since The Issues Involved In All The Appeals Are Interconnected & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Common Order.

272A(1)(d) of the Income Tax Act (hereinafter referred to as the ‘Act’) respectively. Since the issues involved in all the appeals are interconnected and relate to the same assessee, therefore, these appeals have been heard together and are being disposed of by this common order. ITA Nos.2066 to 2071/Kol/2025 Ishtiyaque Ahmed 2. ITA No.2066/Kol/2025 - Facts in brief

ISHTIYAQUE AHMED,KOLKATA vs. DCIT/ACIT, CC-4(3),, KOLKATA

In the result, all the captioned appeals of the assessee are allowed

Disallowed capital balance by Rs.3,19,671/-\n8. Aggrieved by the said order, the assessee preferred an appeal\nbefore the ld. CIT(A) wherein the ld. CIT(A) confirmed the additions so\nmade by the Assessing Officer.\n9. Aggrieved and dissatisfied, the assessee has come in appeal before\nus. The ld. AR submits that the Assessing Officer on the basis