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

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 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 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

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

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