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

10% of Assured sum as premium amount was amended through Finance Act, 2012 w.e.f. 01.04.2013. The Provision of section 80C(5) is not applicable in this case as the policy was surrendered after more than 5 years on 30.04.2016. M/s Reliance Nippon had deducted TDS

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) ..

5) has thus committed no illegality and the CIT(A) was right in deleting the illegal addition made by the AO. 13.3. The quantum of deduction claimed under section 80lA will be the same even if the transaction of loan is ignored. 13.3.1. Even if the Assessee would not have granted interest-free ICD to its sister concern, then

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) ..

5) has thus committed no illegality and the CIT(A) was right in deleting the illegal addition made by the AO. 13.3. The quantum of deduction claimed under section 80lA will be the same even if the transaction of loan is ignored. 13.3.1. Even if the Assessee would not have granted interest-free ICD to its sister concern, then

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) 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

5) & (6) of Section 9B of the Mining and Minerals (Development and Regulation) Act, 1957 had pursuant to Notification F. No.16/7/2015- M.VI dated 17.09.2015 created “District Mineral Foundation” (“DMF”, for short) in December 2015. Also, it was observed by him that the Ministry of Coal in exercise of powers conferred by sub-section (2), (3) and (4) of Section