M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

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

section 153A(1) read with „Expln-2‟; in absence of this, assessment made u/s153C would be invalid & is liable to be quashed; relied on Goldstone Cements Ltd (2023) (Gau HC); Fortune Vanijya (P) Ltd (2023) (Gau HC).” 40. In the appeal of the assessee bearing ITA No.111/Nag/ 2024, for the assessment year 2012-13 along with following additional ground

M/S MAHESHWARI COAL BENEFICATION& INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

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

section 153A(1) read with „Expln-2‟; in absence of this, assessment made u/s153C would be invalid & is liable to be quashed; relied on Goldstone Cements Ltd (2023) (Gau HC); Fortune Vanijya (P) Ltd (2023) (Gau HC).” 40. In the appeal of the assessee bearing ITA No.111/Nag/ 2024, for the assessment year 2012-13 along with following additional ground

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. DCIT CENTRAL CIRCLE-1(1), NAGPUR

In the result, appeals for the assessment year 2009–10 to 2013–14 are partly allowed

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

section 153A(1) read with „Expln-2‟; in absence of this, assessment made u/s153C would be invalid & is liable to be quashed; relied on Goldstone Cements Ltd (2023) (Gau HC); Fortune Vanijya (P) Ltd (2023) (Gau HC).” 40. In the appeal of the assessee bearing ITA No.111/Nag/ 2024, for the assessment year 2012-13 along with following additional ground

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCIT ACIT CIRCLE-3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED THROUGH ITS ERSTWHILE DIRECTOR PRASHANT NATWARLAL LAKHANI,NAGPUR vs. DCITACIT CIRCLE-3 , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, , NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ADITI EXPRESS CARGO INDIA PRIVATE LIMITED,NAGPUR vs. DCIT ACIT CIRCLE -3, NAGPUR

In the result, all the captioned seven appeal are allowed for statistical purposes

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

144 Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.559/Nag./2024 Faceless 6. 23/09/2024 271(1)(b) Appeal A.Y. 2014–15 by Assessee Centre, Delhi National ITA no.560/Nag./2024 Faceless 7. 23/09/2024 271(1)(c) Appeal A.Y. 2014–15 by Assessee Centre, Delhi We take up appeal in ITA no.498/Nag./2024, for the assessment year

ASHOKKUMAR GOKULCHAND SANANDA,BULDHANA vs. ASSISTANT COMMISIONER OF INCOME TAX AKOLA CIRCLE, AKOLA

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Royashokkumar Gokulchand Acit, Akola Circle, Akola Sananda, Rana Traders, Vs Gandhi Chowk, Khamgaon, Dist. Buldhan, Khamgaon Pan : Adpps 755I L Assessee Respondent Assessee By : Shri K.P. Dewani, Adv Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 20.02.2026 Date Of Pronouncement : 06.04.2026

disallowing the claim of deduction u/s 35(1)(ii) of I.T. Act 1961 is not in accordance with law. i) Bombay High Court order in ITA No.05 of 2025 in the case of M/s CDET Explosive Industries Pvt. Ltd. vide order dated 24/12/2025. (P- 1) [Vol.- B] ii) ITAT order in ITA Nos.310 to 312/Nag/2019 in the case

M/S TAWARI TRADERS ,BULDHANA vs. INCOME TAX OFFICER WARD -2, KHAMGAON

In the result, appeal by the assessee stands dismissed

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

144), Kundan Traders. Malkapur (Rs.3,24,743), Mahesh Metal Container (Rs.5,43,148) relates to earlier years. Hence, it can be easily and conveniently 3 M/s. Tiwari Traders ITA no.193/Nag./2019 interpreted that no borrowed funds of current years are invested in the said advances. Therefore, there is no question of charging any interest or there is no question

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P. LTD,BILASPUR vs. ACIT CENTRAL CIRCLE-1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year

M/S MAHESHWARI COAL BENEFICATION & INFRASTRUCTURE P LTD.,BILASPUR vs. ACIT CENTRAL CIRCLE 1(1), NAGPUR

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

section 153D dated 29/09/2021 is in mechanical/routine manner without application of mind by Addl.CIT, which is merely a formality, an empty ritual and as such it leads to flagrant violation of the rules of law. 45. The third contention of the learned A.R. is that while granting such mechanical approval dated 29/09/2021 under section 153D for the assessment year