DY. C.I.T. CENTRAL CIR2(2), NAGPUR vs. M/S SHREE AGRAWAL COAL INDIA PVT. LTD.,, NAGPUR

In the result, Revenue’s appeal being ITA no

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of Rs. 1,27,653/-. 5. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition

A,C.I.T. CENTRAL CIR.- 2(2), NAGPUR vs. SHRI DHARAMPAL R.AGRAWAL, NAGPUR

In the result, Revenue’s appeal being ITA no

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of Rs. 1,27,653/-. 5. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition

SUFALAM INFRA PROJECTS LTD ,NAGPUR vs. PR. CIT (CENTRAL ), NAGPUR

In the result, the departmental appeal is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of the Act from 01-04-1984 came up for consideration in Allied Motors Private Limited v. CIT (1997) 91 taxman 205(SC) before Hon'ble Supreme Court and it was given retrospective effect from the inception of the section on the reasoning that the proviso was added to remedy ITA NO.97/NAG/2019 & ITA NO. 46/NAG/2021 & CO NO.6/NAG/2023 Sufalam Infra

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), NAGPUR, NAGPUR vs. M/S. SUFLAM INFRA PROJECT LTD, NAGPUR

In the result, the departmental appeal is dismissed

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of the Act from 01-04-1984 came up for consideration in Allied Motors Private Limited v. CIT (1997) 91 taxman 205(SC) before Hon'ble Supreme Court and it was given retrospective effect from the inception of the section on the reasoning that the proviso was added to remedy ITA NO.97/NAG/2019 & ITA NO. 46/NAG/2021 & CO NO.6/NAG/2023 Sufalam Infra

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. M/S SHREE AGRAWAL FINANCE INDIA P. LTD.,, NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of Rs. 1,27,653/-. 5. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition

DY. C.I.T. CENTRAL CIR.-2(2), NAGPUR vs. M/S SHREE AGRAWAL FINANCE INDIA P. LTD.,, NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of Rs. 1,27,653/-. 5. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition

A,C.I.T. CENTRAL CIR.- 2(2), NAGPUR vs. SHRI DHARAMPAL R.AGRAWAL, NAGPUR

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

43B of Rs. 1,27,653/-. 5. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition