DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCEL-1(2, NAGPUR vs. M/S. VIBRANT GLOBAL CAPITAL LTD., MUMBAI

In the result, appeal filed by the Revenue is dismissed

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

58) B) The assessee company is having share capital, reserve & surplus and interest free funds at Rs.62.55 crore. The investment in shares and securities is Rs.32.98 crore [P-67 of impugned order of CIT(A)]. Investment in shares can be reasonably explained with reference to available funds. No disallowance out of interest can be made under the provisions of section

M/S SHREE STEEL CQASTINGS PVT. LTD ,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -1, NAGPUR

In the result, Assessee’s appeal is partly allowed

Bench: Shri Narender Kumar Choudhrym/S. Shree Steel Castings Dcit, Circle-1, Nagpur Pvt. Ltd., T/38/1, Midc, Vs. Hingna Road, Nagpur. Pan: Aaccs 4071 J (Appellant) (Respondent)

58,244/- on account of disallowance of interest by picking revise of the provision of 8D of the Income Tax Rules, 1962 (in short, ‘Rules’) read with section

SUNRISE STRUCTURALS & ENGINEERING PVT LTD,NAGPUR vs. ASSISTANT/ DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4 NAGPUR, NAGPUR

In the result, appeal filed by the assessee stands allowed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roysunrise Structural & Acit/Dcit, Circle-4, Engineering P. Ltd., A10, Vs Nagpur Hingna Midc, Nagpur (Urban), Nagpur-440016 Pan : Aaccs 3220 M Assessee Respondent Assessee By : Shri K.P. Dewani, Advocate Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 10.04.2026 O R D E R

58,435/- by invoking provisions of section 69C of I.T. Act 1961. It is undisputed fact on record 11 that transaction of purchase is recorded in books of account. Source for payment of such expenditure is working capital/fund available in books of account. Books of account of the assessee are not rejected and have not invited any adverse observation

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

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

section should be allowed if the appellant had made any provision towards bad and doubtful debts and not necessarily equivalent to the provision made as held by Hon'ble ITAT Delhi in case of Pratima Bank (58 ITR (Trib) 1). 2.2 Without prejudice to the above, the CIT(A) should have allowed the alternate claim of the appellant that

VIDHARBHA KONKAN GRAMIN BANK ,NAGPUR vs. INCOME TAX OFFICER WARD 1(5) , NAGPUR

In the result, appeal filed by the assessee for A

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

section should be allowed if the appellant had made any provision towards bad and doubtful debts and not necessarily equivalent to the provision made as held by Hon'ble ITAT Delhi in case of Pratima Bank (58 ITR (Trib) 1). 2.2 Without prejudice to the above, the CIT(A) should have allowed the alternate claim of the appellant that

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -1,RAIPUR (CG), RAIPUR (CG) vs. M/S SARDA ENERGY & MINERALS LTD , NAGPUR

The appeals of the Revenue are dismissed

section 14A of the Act are the issues raised in the scrutiny assessment. At the end of the assessment, the Assessing Officer made the following additions :- “4. Subject to the above remarks, total income of the assessee company is computed as under :- Income as per return of income Rs. 39,92,030/- Add: (1) Disallowance u/s.80IA(8) Rs.3

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -1,RAIPUR (CG), RAIPUR (CG) vs. M/S SARDA ENERGY & MINERALS LTD , NAGPUR

The appeals of the Revenue are dismissed

section 14A of the Act are the issues raised in the scrutiny assessment. At the end of the assessment, the Assessing Officer made the following additions :- “4. Subject to the above remarks, total income of the assessee company is computed as under :- Income as per return of income Rs. 39,92,030/- Add: (1) Disallowance u/s.80IA(8) Rs.3

ACIT, CIRCLE-4, NAGPUR vs. M/S NANDLAL ENTERPRISES, NAGPUR

In the result, appeal of Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

58,24,560/- had been disallowed u/s.40(a)(ia) of the I T Act. The AR of the assessee in this regard has submitted a ledger of freight payments to the truck operators and it is evident from the same that none of the payments exceeded Rs.50,000/- to any particular truck operator and thus the assessee company

ACIT, CIRCLE-4, NAGPUR vs. M/S NANDLAL ENTERPRISES, NAGPUR

In the result, appeal of Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

58,24,560/- had been disallowed u/s.40(a)(ia) of the I T Act. The AR of the assessee in this regard has submitted a ledger of freight payments to the truck operators and it is evident from the same that none of the payments exceeded Rs.50,000/- to any particular truck operator and thus the assessee company

ACIT, CIRCLE-4, NAGPUR vs. M/S NANDLAL ENTERPRISES, NAGPUR

In the result, appeal of Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm

58,24,560/- had been disallowed u/s.40(a)(ia) of the I T Act. The AR of the assessee in this regard has submitted a ledger of freight payments to the truck operators and it is evident from the same that none of the payments exceeded Rs.50,000/- to any particular truck operator and thus the assessee company

RAHUL UDYOG,AMRAVATI vs. INCOME TAX OFFICER,WARD-2, AMRAVATI

In the result, the ground no

Bench: Shri Vikram Singh Yadav & Shri Yogesh Kumar U.S

58,320/- & Bardana purchase Rs. 2,38,050/- u/s. 40A(3) irrespective of the fact that payment to individual person is below Rs. 20,000/- and provision of sec. 40A(3) not applicable in his case. 3. The Ld CIT (Appeals) erred in restricting the interest paid to relatives from 18% to 15% u/s. 40A(2) and thereby disallowing

RAVINDRA MADANLAL KHANDELWAL,AKOLA vs. DCIT/ACIT CIRCLE , AKOLA

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

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

disallowed the entire expenses by stating that interest bearing funds was used for non-business activity. In this regard we humbly wish to submit that the interest-bearing funds i.e., secured as well as unsecured are used for business of the related concern (i.e.) private limited company Khandelwal Jewellers Akola Private Limited. 3.3 The term for business purpose, used

JAI SUBHASH NAGARI SAHAKARI PAT SANSTHA MARYADIT,NAGPUR vs. ITO WARD-1(2), NAGPUR

In the result, appeal filed by the assessee is allowed

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

58,17,740, which was claimed as exempt under section 80P of the Act. The said disallowance was confirmed by the learned

NIKITA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Ms. Nikita Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Borpt 4644 F Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 /6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Passed Is Illegal, Invalid & Bad In Law.

58 CCH 0073 (Bang.Trib) 10 ITA No.155/NAG.2021 Nikita Shankarlal Tanwani vs ACIT, Central Circle-2(1), Nagpur ii) Honey Rahulan v/s ITO, ITA No. 150/Coch/2020 dated 09/06/2020 iii) Syed Khalid Saifullah v/s. ITO, [2020] TaxPub(DT) 2006 (Del- Trib); iv) SaurabhMalhotra v/s. ITO, ITA No. 72/Agra/2016 dated 28/02/2018; v) Syed Maqsoodulla v/s. ITO, ITA No. 397/Bang/2019 dated 11/09/2020

SHRI ANKIT SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANAT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Shri Ankit Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Biapt 4756 R Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8/6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Assessee Has Filed The Present Appeal On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

58 CCH 0073 (Bang.Trib) ii) Honey Rahulan v/s ITO, ITA No. 150/Coch/2020 dated 09/06/2020 iii) Syed Khalid Saifullah v/s. ITO, [2020] TaxPub(DT) 2006 (Del-Trib); iv) SaurabhMalhotra v/s. ITO, ITA No. 72/Agra/2016 dated 28/02/2018; v) Syed Maqsoodulla v/s. ITO, ITA No. 397/Bang/2019 dated 11/09/2020 vi) Om PrakashKarnani v/s. ACIT [2021] TaxPub(DT) 0841 (JP-Trib); vii) DineshkumarVerma

ANKIT SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Shri Ankit Shankar Lal Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar, Pandhuna Pandhurna Nagpur Chhindwara – 480 334 (M.P.) Pan No.:Biapt 4756 R Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Captioned Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

58 CCH 0073 (Bang.Trib) ii) Honey Rahulan v/s ITO, ITA No. 150/Coch/2020 dated 09/06/2020 iii) Syed Khalid Saifullah v/s. ITO, [2020] TaxPub(DT) 2006 (Del-Trib); iv) SaurabhMalhotra v/s. ITO, ITA No. 72/Agra/2016 dated 28/02/2018; v) Syed Maqsoodulla v/s. ITO, ITA No. 397/Bang/2019 dated 11/09/2020 vi) Om PrakashKarnani v/s. ACIT [2021] TaxPub(DT) 0841 (JP-Trib); vii) DineshkumarVerma

HARSHA SANTOSH TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is partly allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2018-19 Shri Harsha Santosh Tanwani Vs. The Acit Near Shankar Mandir, Shankar Central Circle 2(1) Nagar,Pandhuna, Nagpur Pandhurna 480334 (M.P.) Pan No.:Bobpt 5794 Q Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2018-19. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

58 CCH 0073 (Bang.Trib) ii) Honey Rahulan v/s ITO, ITA No. 150/Coch/2020 dated 09/06/2020 iii) Syed Khalid Saifullah v/s. ITO, [2020] TaxPub(DT) 2006 (Del-Trib); iv) SaurabhMalhotra v/s. ITO, dated 28/02/2018; v) Syed Maqsoodulla v/s. ITO, ITA No. 397/Bang/2019 dated 11/09/2020 vi) Om PrakashKarnani v/s. ACIT [2021] TaxPub(DT) 0841 (JP-Trib); vii) DineshkumarVerma v/s. ITO, ITA No. 1183/Mum/2019

ASHA SHANKARLAL TANWANI,CHHINDWARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, NAGPUR

In the result, assessee’s appeal is party allowed

Bench: Shri Sandeep Gosain, Jm & Shri Arun Khodpia, Am Assessment Year: 2019-20 Smt. Asha Shankarlal Tanwani Vs. The Acit 01, Shankar Nagar, Pandhuna Central Circle 2(1) Chhindwara – 480 334 (M.P.) Nagpur Pan No.:Bnvpt 1763 J Appellant Respondent Assessee By: Shri Manoj G. Moryani, Adv. & Shri Bhavesh Moryani, Adv Revenue By :Shri Piyush Kolhe (Cit-Dr) Date Of Hearing: 28/04/2022 Date Of Pronouncement: 8 / 6 /2022 Order Per: Sandeep Gosain, J.M. The Aforesaid Appeal By The Assessee Challenging The Impugned Order Dated 8Th October 2021, Passed By The Commissioner Of Income Tax (Appeals)–3, Nagpur, [In Short “The Learned Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 (In Short "The Act") For The Assessment Year 2019-20. The Present Appeal Has Been Filed On The Following Grounds:- 2. “1. The Commissioner Of Income Tax (Appeals)-3, Nagpur Erred In Confirming Addition, Therefore Order Passed Is Illegal, Invalid & Bad In Law.

58 CCH 0073 (Bang.Trib) ii) Honey Rahulan v/s ITO, ITA No. 150/Coch/2020 dated 09/06/2020 iii) Syed Khalid Saifullah v/s. ITO, [2020] TaxPub(DT) 2006 (Del-Trib); iv) SaurabhMalhotra v/s. ITO, dated 28/02/2018; v) Syed Maqsoodulla v/s. ITO, ITA No. 397/Bang/2019 dated 11/09/2020 vi) Om PrakashKarnani v/s. ACIT [2021] TaxPub(DT) 0841 (JP-Trib); vii) DineshkumarVerma v/s. ITO, ITA No. 1183/Mum/2019