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) ..

iii) as well as in the working of profit earned from eligible business for claim of deduction u/s. 80lA of the Act. While the contentions of the appellant have force I find that the AO has not brought on record any credible instances in support of his observations on the business arrangement being such between the appellant and the associate

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) ..

iii) as well as in the working of profit earned from eligible business for claim of deduction u/s. 80lA of the Act. While the contentions of the appellant have force I find that the AO has not brought on record any credible instances in support of his observations on the business arrangement being such between the appellant and the associate

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

In the result, appeal of the assessee company is allowed for statistical purposes in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 43/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

10. Without prejudice to the above, the Ld. CIT(A), NFAC erred in not adjudicating the ground raised for initiating penalty proceedings on account of disallowance of depreciation on railway siding leased to M/s Aryan Coal Beneficiation Pvt. Ltd, M/s Gujarat State Electricity Board and M/s Spectrum Coal & Power Limited. 11. Without prejudice to the above

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

iii) Webtrust Co. Inc (India) Pvt. Ltd. ACIT, CPC (TDS) in ITA Nos.1818 & 1819/PUN/2018 for Assessment Years 2013-14 & 2014-15, order dated 02.11.2021 as well as the decision of the Co-ordinate Bench of the Tribunal, Raipur in the case of EE RES Division Rajnandgaon, Collectorate Vs. The DCIT (CPC/TDS), Ghaziabad, ITA Nos. 255 to 257/RPR/2022, dated

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

iii) Webtrust Co. Inc (India) Pvt. Ltd. ACIT, CPC (TDS) in ITA Nos.1818 & 1819/PUN/2018 for Assessment Years 2013-14 & 2014-15, order dated 02.11.2021 as well as the decision of the Co-ordinate Bench of the Tribunal, Raipur in the case of EE RES Division Rajnandgaon, Collectorate Vs. The DCIT (CPC/TDS), Ghaziabad, ITA Nos. 255 to 257/RPR/2022, dated

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

iii) Webtrust Co. Inc (India) Pvt. Ltd. ACIT, CPC (TDS) in ITA Nos.1818 & 1819/PUN/2018 for Assessment Years 2013-14 & 2014-15, order dated 02.11.2021 as well as the decision of the Co-ordinate Bench of the Tribunal, Raipur in the case of EE RES Division Rajnandgaon, Collectorate Vs. The DCIT (CPC/TDS), Ghaziabad, ITA Nos. 255 to 257/RPR/2022, dated

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

iii). receipts on account of other factors, thus, he had failed to distinguish the amounts, if any, which it had collected towards penalty/fine vis-a-vis that received towards value of minerals. The A.O on the basis of his exhaustive deliberations concluded that as the assessee as per the mandate of sub-section (1C) of Section