SHAKTI RANJAN DASH,BHUBANESWAR V. DCIT, CIRCLE-1(1), BHUBANESWAR

ITA 33/CTK/2026

AI Insights

The case involves appeals by the assessee, Shakti Ranjan Dash, against the orders of the CIT(A), which confirmed the disallowances made by the Assessing Officer for the assessment years 2013-14 and 2014-15. The disallowances were related to amounts received by the assessee from two companies, Anmol Resources Pvt Ltd. and Anmol Mines Pvt Ltd., where the assessee was a director. The Assessing Officer had treated these receipts as unaccounted salary advances, leading to their disallowance. The Tribunal, however, accepted the assessee's argument that these were advances for expenses incurred on behalf of the companies, leading to the deletion of the additions.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 841002 (ITAT-CUTTACK)
• Duration Of Justice: 1 month(s) 12 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2014-2015
• Appeal Filed On: 13-01-2026
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Salary income

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH CUTTACK BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER ITA Nos. 32 & 33/CTK/2026 (Assessment Years: 2013-14 & 2014-15) Shakti Ranjan Dash, C-111, Basanta Park, Forest Park, Bhubaneswar. PAN No.AEOPD 6102 Q Vs. DCIT, Circle-1(1), Aayakar Bhawan, Bhubaneswar. Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri Chitrasen Parida, Adv. Department represented by Shri Sanjib Banerjee, Sr.DR Date of hearing 25/02/2026 Date of pronouncement 25/02/2026 O R D E R PER: BENCH 1. These are appeals filed by the assessee against the separate orders of the ld. CIT(A), NFAC, Delhi in Appeal Nos. NFAC/2012-13/10063353 and NFAC/2013-14/10071093, both dated 10/11/2025 for the A.Ys. 2013-14 & 2014-15, respectively. 2. Shri Chitrasen Parida, ld. A.R. is appeared on behalf of the assessee and Shri Sanjib Banerjee, ld. Sr.DR represented on behalf of the revenue. 3. It was submitted by ld AR that for the assessment year 2013-14, the assessee had received Rs.7,00,000/- from Anmol Resources Pvt Ltd., a concern, in which the assessee was a director and an amount of Rs.1,00,000/- from Anmol Mines Pvt Ltd., where the assessee was a director. It was the submission that the Assessing Officer disallowed Rs.2,80,000/- Printed from counselvise.com ITA Nos.32 & 33/Ctk/2026 2 out of the amount received from Anmol Resources Pvt Ltd., and entire amount of Rs.1,00,000/- received from Anmol Mines Pvt Ltd. It was the further submission that similarly for the assessment year 2014-15, the assessee had received Rs.5,40,000/- from Anmol Resources Pvt Ltd., and Rs.1,30,000/- from Anmol Mines Pvt Ltd., and the Assessing Officer had disallowed Rs.3,00,000/- out of the receipts from Anmol Resources Pvt Ltd., and entire amount of Rs.1,30,000/- from Anmol Mines Pvt Ltd., It was the submission that the Assessing Officer took the stand that the assessee has shown the amounts were received as advance against salary for the assessment year 2013-14 & 2014-15 and the assessee has not shown any salary income. It was the submission that these were basically advance received from the said two companies for expenses. In regard to expenses, it was the submission that the amounts were incurred by the assessee on behalf of two companies. It was the submission that the addition as made by the AO and confirmed by ld CIT(A) is liable to be deleted. 4. In reply, ld Sr.DR vehemently supported the orders of the Assessing Officer and ld. CIT(A). It was the submission that the assessee has not provided any details before the AO and ld CIT(A). 5. We have considered the rival submissions. Considering the nominal nature of the addition as also the clear admission by the assessee that these are advances for the expenses made by the assessee on behalf of two companies, the addition as made by the AO and confirmed by ld CIT(A) stands deleted. Printed from counselvise.com ITA Nos.32 & 33/Ctk/2026 3 6. In the result, both the appeals of the assessee are allowed. Order dictated and pronounced in the open court on 25/02/2026. Sd/- Sd/- (MADHUSUDAN SAWDIA) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Cuttack, Dated: 17/02/2026 *Ranjan, Sr. PS Copy to: 1. Assessee - Shakti Ranjan Dash,C-111, Basanta Park, Forest Park, Bhubaneswar 2. Revenue- DCIT, Circle-1(1), Aayakar Bhawan, Bhubaneswar 3. CIT(A), NFAC, Delhi 4. CIT 5. DR 6. Guard File By Order Assistant Registrar, ITAT, Cuttack Printed from counselvise.com "