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) ..

section 80IA(10) could not be invoked. The hon‟ble Allahabad High Court in Commissioner of Income Tax Meerut vs. Translam ltd. Reported in 52 taxmann.com 357 (Allahabad) held that where assessee company had maintained separate accounts for each unit and further assessing officer could not prove that business between eligible unit and other units of the assessee were

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) ..

section 80IA(10) could not be invoked. The hon‟ble Allahabad High Court in Commissioner of Income Tax Meerut vs. Translam ltd. Reported in 52 taxmann.com 357 (Allahabad) held that where assessee company had maintained separate accounts for each unit and further assessing officer could not prove that business between eligible unit and other units of the assessee were

MITESH SINGHANIA,RAIPUR vs. INCOME TAX OFFICER WARD 1(2) RAIPUR, CENTRAL REVENUE BUILDING, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.410/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Mitesh Singhania Singhania Bhawan, Subhas Road, Near Telghani Naka, Raipur (C.G.)-492 001 Pan: Avops1474P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G) ……""यथ" / Respondent

TDS under section 194DA in spite of the fact that whole sum was exempt under section 10(10D) and there

PADMA PARAKH, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, TDS, BHILAI, BHILAI

In the result, all the appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

section 234E of the Act. Hence, the said decision relied upon by the revenue is misplaced so far as the facts of the assessee’s case are concerned. 9 Padma Parakh Vs. ITO (TDS) ITA Nos. 560, 561 & 562/RPR/2025 10

PADMA PARAKH, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, TDS, BHILAI, BHILAI

In the result, all the appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

section 234E of the Act. Hence, the said decision relied upon by the revenue is misplaced so far as the facts of the assessee’s case are concerned. 9 Padma Parakh Vs. ITO (TDS) ITA Nos. 560, 561 & 562/RPR/2025 10

PADMA PARAKH, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, TDS, BHILAI, BHILAI

In the result, all the appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

section 234E of the Act. Hence, the said decision relied upon by the revenue is misplaced so far as the facts of the assessee’s case are concerned. 9 Padma Parakh Vs. ITO (TDS) ITA Nos. 560, 561 & 562/RPR/2025 10

DISTRICT MINING OFFICER, BEMETARA,BEMETARA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BEMETARA,BEMETARA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BEMETARA,BEMETARA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, DANTEWADA,DANTEWADA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BIJAPUR,BIJAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BEMETARA,BEMETARA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, DANTEWADA,DANTEWADA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, DANTEWADA,DANTEWADA vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BIJAPUR,BIJAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DEPUTY DIRECTOR (GEOLOGY & MINING), RAIPUR,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS/TCS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DEPUTY DIRECTOR (GEOLOGY & MINING), RAIPUR,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS/TCS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DISTRICT MINING OFFICER, BIJAPUR,BIJAPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds

DEPUTY DIRECTOR (GEOLOGY & MINING), RAIPUR,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (TDS/TCS), RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 10 of Contract Act, plea of assessee was be upheld- Held yes [in favour of the Revenue] b. In the High Court of Madhya Pradesh in the case of Executive Engineer, PWD (nh) Divisions. Recovery Officer, tds