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

disallowed u/s. 14A, r.w. Rule 8D as discussed above. Penalty proceedings u/s.271(1)(c) are separately initiated as the assessee has filed inaccurate particulars of its income.” 8. Aggrieved with the above addition, the assessee filed an appeal before the CIT(A). The CIT(A) deleted the addition of Rs.3,85,95,867/- u/s 80IA(8) of the Act relying

SANJAY GULABCHAND GUPTA,NAGPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-4, NAGPUR

In the result, appeal by the assessee stands dismissed

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

Section 54 must be completed within three years after the transfer of original assets. (Para 4.13 AO's Order) & 4.16 of A.O’s order) 5. Land use was for Commercial purposes. 4. So basically there is no dispute as regards calculations of Capital gains. However the claim of exemption u/s 54F is disallowed for above reasons. Pertinent to note

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

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

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

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

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

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

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

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

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

SHRI SANJAY DHANRAJ JAIN,NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), NAGPUR

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

disallowance whatsoever is made in the same. Further, no notice u/s 143(2) of the Income Tax Act was issued for conducting assessment. In view of above, assessment of the appellant is completed and had attained finality. The assessment was not abated at the time of initiation of search action u/s 132 of the Act and as a result

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

234). No independent enquiry is made before recording satisfaction for escapement of income. Reasons recorded merely on the basis of report of DGGI Zone unit, Nagpur is not in accordance with law. Reopening notice has to be issued by A.O on his own satisfaction and not on borrowed satisfaction. Reliance on: i) (2023) (156 taxmann.com 221) (Bombay HC) Gandhibag Sahakari

BHARTI MAIND NAGRI SAHAKARI PAT SANSTHA,YAVATMAL vs. INCOME TAX OFFICE , NATIONAL E ASSESSMENT, NEW DELHI

In the result, appeal filed by the assessee for the assessment year

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

disallowances is eligible for deduction u/s 80P(2)(a)(i) of the Income Tax act'1961. 5) Interest u/s 234A, 234 B and 234 C of the Income Tax act '1961 being consequential in nature needs to be deleted. 6) Assessee craves leave to add, alter or amend any of the grounds of appeal.” 3. Facts in Brief:– The assessee

BHARTI MAIND NAGRI SAHAKARI PAT SANSTHA,YAVATMAL vs. INCOME TAX OFFICER, NATIONAL E ASSESSMENT , YAVATMAL

In the result, appeal filed by the assessee for the assessment year

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

disallowances is eligible for deduction u/s 80P(2)(a)(i) of the Income Tax act'1961. 5) Interest u/s 234A, 234 B and 234 C of the Income Tax act '1961 being consequential in nature needs to be deleted. 6) Assessee craves leave to add, alter or amend any of the grounds of appeal.” 3. Facts in Brief:– The assessee

ASSTT.COMMISSIONER OF INCOME TAX ,CIRCLE-4, NAGPUR vs. SHRI NANDLAL B MALOO, NAGPUR

In the result, assessee’s cross objection is partly allowed

Bench: Shri P.K. Bansal & Shri Amarjit Singh

disallowing the payment of commission of ` 5,05,835. ISSUE NO.1 9. Under this issue, the assessee has challenged the re–opening of assessment under section 147 / 148 of the Act. The re–opening was 11 Shri Nandlal B. Maloo made on the basis of letter dated 3rd February 2007 filed by the learned Counsel for assessee in which

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