IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE VIVEK RUSIA &

HON'BLE SHRI JUSTICE PRADEEP MITTAL INCOME TAX APPEAL No. 32 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATIONAL HIGHWASYS AUTHORIY OF INDIA PIU NARSINGHPUR SHRI RAMDAS BHAWAN Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

WITH INCOME TAX APPEAL No. 33 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATINAL HIGHWAYS AUTHORITY OF INDIA PIU NARSINGHPUR S Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 34 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATIONAL HIGHWASY AUTHORITY OF INDIA PIU NARSINGHPUR Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 35 of 2014 COMMISSIONER OF INCOME TAX INCOME TAX DEPARTMENT Versus AUTHORITY OF INDIA PIU NARSINGHPUR PROJECT DIRECTOR NATIONAL HIGHWAYS Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 36 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATIONAL HIGHWAYS AUTHORITY OF INDIA PIU NARSINGHPUR Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 37 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATIONAL HIGHWAYS AUTHORITY OF INDIA PIU NARSINGHPUR Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 38 of 2014 COMMISSIONER OF INCOME TAX TDS Versus PROJECT DIRECTOR NATIONAL HIGHWASY AUTHORITY OF INDIA PIU NARSINGHPUR Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 39 of 2014 COMMISSIONER OF INCOME TAX TDS Versus M/S NATIONAL HIGHWASY AUTHORTY OF INDIA NATIONAL HIGHWAYS OF INDIA Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

INCOME TAX APPEAL No. 40 of 2014 COMMISSIONER OF INCOME TAX TDS Versus M/S NATIONAL HIGHWAYS AUTHORITY OF INDIA NATIONAL AUTHORITY OF INIDA Appearance:

Shri Siddharth Sharma - Advocate for the appellant.

Shri Sumit Nema - Senior Advocate with Shri Abhijeet Shrivastava and Shri Ayush Gupta - Advocates for the respondent.

RESERVED ON: 25.02.2026 PRONOUNCED ON: 06.03.2026 --------------------------------------------------------------------------------------------------

ORDER Per: Justice Vivek Rusia These bunch of income tax appeals are filed by the Commissioner of Income Tax, (TDS), Bhopal, (M.P.) under Section 260-A of the Income Tax Act, 1961 in respect of assessment years 2008-09 and 2009-10 challenging the orders dated 12.09.2013 and 20.09.2013 passed by the Income Tax Appellate Tribunal, Jabalpur (for short 'Tribunal') in I.T.A. No.70/Jbp/2013, 73/Jbp/2013, 69/Jbp/2013, 72/Jbp/2013, 67/Jbp/2013, 71/Jbp/2013, 68/Jbp/2013, 22/Jbp/2012 and 23/Jbp/2012. As these appeals involve an identical issue, they are heard analogously and are being decided by this common order.

Facts of these cases are being taken from I.T.A. No.32/2014:-

2. M/s Ssangyong Engineering and Construction Company Ltd. (hereinafter referred to as 'deductee company') entered into a contract with