NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

NIKITA KINGRANI, DURG,DURG vs. INCOME TAX OFFICER-TDS WARD, BHILAI, DURG

In the result, all the appeals of the assessee are dismissed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section provides as follows: - Form of appeal and limitation. "249. (1) Every appeal under this Chapter shall be in the prescribed form 61-and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 4 Nikita Kingrani Vs. DCIT, CPC-TDS, Ghaziabad

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

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) ..

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

RAJESH KUMAR SINGHANIA HUF,RAIPUR vs. INCOME TAX OFFICER, WARD 1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.848/Rpr/2025 "नधा"रण वष" / Assessment Year : 2018-19 Rajesh Kumar Singhania Huf B-22/12, Sector-3, Udaya Society, Tatibandh, Raipur (C.G.) Pan: Aadhr1548F

2. At the very outset, it is noted that the appeal is time barred by 30 days, for which, the assessee had filed condonation application a/w. affidavit dated 31.12.2025. The relevant part of the said affidavit is extracted as follows: 3 Rajesh Kumar Singhania HUF Vs. ITO, Ward-1(1), Raipur (C.G.) 4 Rajesh Kumar Singhania HUF Vs. ITO, Ward

DISTRICT PROJECT LIVELIHOOD COLLEGE SOCIETY,GARIYABANDH(CG) vs. INCOME TAX OFFICER (TDS),RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 271, 272 & 273/Rpr/2025 (िनधा"रण वष" Assessment Years: 2016-17, 2017-18, 2018-19)

2) was pending before the tribunal cannot justify the delay in filing of appeal before the High Court. The appellant was required to furnish the sufficient cause together with the evidence for the claim made. This has not been done. Therefore, it held that the reasons given for condonation of delay does not tantamount to sufficient cause within the meaning

DISTRICT PROJECT LIVELIHOOD COLLEGE SOCIETY,GARIYABANDH (C.G) vs. INCOME TAX OFFICER (TDS),RAIPUR, AYKAR BHAWAN

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 271, 272 & 273/Rpr/2025 (िनधा"रण वष" Assessment Years: 2016-17, 2017-18, 2018-19)

2) was pending before the tribunal cannot justify the delay in filing of appeal before the High Court. The appellant was required to furnish the sufficient cause together with the evidence for the claim made. This has not been done. Therefore, it held that the reasons given for condonation of delay does not tantamount to sufficient cause within the meaning

DISTRICT PROJECT LIVELIHOOD COLLEGE SOCIETY,GARIYABANDH vs. INCOME TAX OFFICER (TDS),RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 271, 272 & 273/Rpr/2025 (िनधा"रण वष" Assessment Years: 2016-17, 2017-18, 2018-19)

2) was pending before the tribunal cannot justify the delay in filing of appeal before the High Court. The appellant was required to furnish the sufficient cause together with the evidence for the claim made. This has not been done. Therefore, it held that the reasons given for condonation of delay does not tantamount to sufficient cause within the meaning

MANISH KUMAR JAIN, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, WARD-1, RAJNANDGAON, RAJNANDGAON

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.516, 517 & 518/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Shri Manish Kumar Jain C/O. Maa Padmavati Rice Industries, Ramadhin Marg, Rajnandgaon-491 441 Pan: Adnpj1476F .......अपीलाथ" / Appellant

2. The Ld. Sr. DR did not raise any objection as regards the condonation of delay involved in the captioned appeals. 3. Having heard the submissions of the parties herein on the ground of limitation, I am of the considered view that such delay has been caused due to technical issue arising from Form 35 itself and it cannot

MANISH KUMAR JAIN, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, WARD-1, RAJNANDGAON, RAJNANDGAON

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.516, 517 & 518/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Shri Manish Kumar Jain C/O. Maa Padmavati Rice Industries, Ramadhin Marg, Rajnandgaon-491 441 Pan: Adnpj1476F .......अपीलाथ" / Appellant

2. The Ld. Sr. DR did not raise any objection as regards the condonation of delay involved in the captioned appeals. 3. Having heard the submissions of the parties herein on the ground of limitation, I am of the considered view that such delay has been caused due to technical issue arising from Form 35 itself and it cannot

MANISH KUMAR JAIN, RAJNANDGOAN,RAJNANDGAON vs. INCOME TAX OFFICER, WARD-1, RAJNANDGAON, RAJNANDGAON

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.516, 517 & 518/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Shri Manish Kumar Jain C/O. Maa Padmavati Rice Industries, Ramadhin Marg, Rajnandgaon-491 441 Pan: Adnpj1476F .......अपीलाथ" / Appellant

2. The Ld. Sr. DR did not raise any objection as regards the condonation of delay involved in the captioned appeals. 3. Having heard the submissions of the parties herein on the ground of limitation, I am of the considered view that such delay has been caused due to technical issue arising from Form 35 itself and it cannot

RAJMAL JAIN, BASTAR,NARAYANPUR vs. INCOME TAX OFFICER, KANKER

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.20 To 29/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2015-16 Rajmal Jain Ward No.3, Tahsilpara, Main Road, Narayanpur, Dist. Bastar Chhattisgarh (C.G.)-494 661 Pan: Aoupj1700Q .......अपीलाथ" / Appellant बनाम / V/S.

2. At the very outset, it is noted that there is delay of 52 days in filing each of the appeals before the Tribunal. That as against the said delay, the Ld. Counsel for the assessee has filed condonation applications. I have carefully perused the contents of the condonation application as well as submissions of the Ld. Counsel. That keeping

RAJMAL JAIN, NARAYANPUR,NARAYANPUR vs. INCOME TAX OFFICER, KANKER

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.20 To 29/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2015-16 Rajmal Jain Ward No.3, Tahsilpara, Main Road, Narayanpur, Dist. Bastar Chhattisgarh (C.G.)-494 661 Pan: Aoupj1700Q .......अपीलाथ" / Appellant बनाम / V/S.

2. At the very outset, it is noted that there is delay of 52 days in filing each of the appeals before the Tribunal. That as against the said delay, the Ld. Counsel for the assessee has filed condonation applications. I have carefully perused the contents of the condonation application as well as submissions of the Ld. Counsel. That keeping

RAJMAL JAIN, NARAYANPUR,NARAYANPUR vs. INCOME TAX OFFICER, KANKER

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.20 To 29/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2015-16 Rajmal Jain Ward No.3, Tahsilpara, Main Road, Narayanpur, Dist. Bastar Chhattisgarh (C.G.)-494 661 Pan: Aoupj1700Q .......अपीलाथ" / Appellant बनाम / V/S.

2. At the very outset, it is noted that there is delay of 52 days in filing each of the appeals before the Tribunal. That as against the said delay, the Ld. Counsel for the assessee has filed condonation applications. I have carefully perused the contents of the condonation application as well as submissions of the Ld. Counsel. That keeping