DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

TDS and few others. The AO has not enquired and established that payments made by the assessee are not genuine. Purpose of section 40A(3) of the Act is to ensure that the payments which are not genuine are not allowed. The AO was also sent the set of account confirmation from all the recipients and his report was called

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

TDS and few others. The AO has not enquired and established that payments made by the assessee are not genuine. Purpose of section 40A(3) of the Act is to ensure that the payments which are not genuine are not allowed. The AO was also sent the set of account confirmation from all the recipients and his report was called

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

TDS and few others. The AO has not enquired and established that payments made by the assessee are not genuine. Purpose of section 40A(3) of the Act is to ensure that the payments which are not genuine are not allowed. The AO was also sent the set of account confirmation from all the recipients and his report was called

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

TDS and few others. The AO has not enquired and established that payments made by the assessee are not genuine. Purpose of section 40A(3) of the Act is to ensure that the payments which are not genuine are not allowed. The AO was also sent the set of account confirmation from all the recipients and his report was called

M/S SMS SHIVNATH INFRASTRUCTURE PVT LTD,DURG(CG) vs. THE PR. COMMISSIONER OF INCOME TAX-2, RAIPUR (CG)

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

TDS under law such disallowance would ultimately increase assessee‟s profits from business of developing housing project. The ultimate profits of assessee after adjusting disallowance under section 40(a)(ia) of the Act would qualify for deduction u/s. 80IE of the Act would qualify for deduction u/s. 80IB of the Act. This view was taken by the courts

THE ASSISTANT COMMISSIONER OF INCOME-TAX-2(1)BHILAI, BHILAI(CG) vs. M/S SMS SHIVNATH INFRASSTRUCTURE PVT LTD., DURG, DURG(CG)

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

TDS under law such disallowance would ultimately increase assessee‟s profits from business of developing housing project. The ultimate profits of assessee after adjusting disallowance under section 40(a)(ia) of the Act would qualify for deduction u/s. 80IE of the Act would qualify for deduction u/s. 80IB of the Act. This view was taken by the courts

GRAMIN SEWA SAHAKARI SAMITI MARYADIT, VILLAGE: TAMASEONI,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEWA SAHAKARI SAMITI MARYADIT,VILL: RISDA, DIST: BALODA BAZAR vs. INCOME TAX OFFICER, BHATAPARA

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEWA SAHAKARI SAMITI MARYADIT,VILL: POND DIST: RAIPUR vs. INCOME TAX OFFICER, WARD- 1(1), RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

THE GRAMIN SEWA SAHAKARI SAMITI MARYADIT,RAIPUR (CG) vs. THE INCOME TAX OFFICER, WARD-1(3),RAIPUR, RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS Rs. 4,15,517/- deducted from commission received on paddy procurement business 4. Disallowance of the assessee’s claim for Rs.5,54,758/- deduction of profit from PDS u/s.80P(2)(c)(ii) of the Act. 5. Disallowance of assessee’s claim for Rs. 23,15,409/- deduction of dividend income u/s.80P(2)(d) of the Act. After making