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

PRIYESH SINGHANIA, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.462/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Priyesh Singhania 730/1, Radha Kunj, Opposite Vip Guest House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 Pan: Aoups7838A ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

TDS was deducted u/s 194DA which is applicable in the case where the maturity proceeds are not eligible for exemption u/s 10(10D). In view of the same, CPC included the amount of Rs.7,41,718/- within taxable income while' processing the return u/s 143(1) of the Act. The appellant claimed that the impugned Intimation

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 was deducted u/s 194DA which is applicable in the case where the maturity proceeds are not eligible for exemption u/s 10(10D). In view of the same, CPC included the amount of Rs.7,41,718/- within taxable income while' processing the return u/s 143(1) of the Act. The appellant claimed that the impugned Intimation

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

25. As such, as recorded earlier, it is on account of the intimation received under Section 200A for making computation and demand of fees under Section 234E, the same has necessitated the appellant to challenge the constitutional validity of Section 234E. When the intimation of the demand notices under Section 200A is held to be without authority

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

25. As such, as recorded earlier, it is on account of the intimation received under Section 200A for making computation and demand of fees under Section 234E, the same has necessitated the appellant to challenge the constitutional validity of Section 234E. When the intimation of the demand notices under Section 200A is held to be without authority

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

25. As such, as recorded earlier, it is on account of the intimation received under Section 200A for making computation and demand of fees under Section 234E, the same has necessitated the appellant to challenge the constitutional validity of Section 234E. When the intimation of the demand notices under Section 200A is held to be without authority

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS) Agra [2012] 25 taxmann.com 187 (Agra) held as under: Even where these is no written contract, liability to TCS arises- Even where assessee city development authority allotted contractors parking lots to run same of assessee to make collection of tax at source under section 206C(1C) “Section 206C of the Income Tax Act, 1961, read with Section