ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)), BHILAI vs. SHRI SANJAY JAIN, BHILAI

In the result ground no. 06 of the revenue stands dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No: Ita 55/Rpr/2020 (Assessment Years:2014-15) Asstt. Commissioner Of Income Tax, V Shri Sanjay Jain, Bhilai S C/O M/S Sidhharth Industries, Plot No. 38, Industrial Estate, Bhilai, C.G. Pan: Aet Pj1859D (अपीलाथ"/Appellant) . (""यथ" / Respondent) . िनधा"रती क" ओर से /Assessee By : Shri Ravi Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing : 23-08-2023 घोषणा क" तार"ख/Date Of : 09-11-2023 Pronouncement

TDS cannot be applied on such payments, consequently, disallowance by invoking the provisions of section 40(a)(ia) was bad in law, thus, the same is directed to be deleted. Ground No. 1 of the revenue is, thus, dismissed in terms of aforesaid observations. 8 Sanjay Jain Ground NO. 2: disallowance u/s 68 for Rs. 1

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1), RAIPUR vs. PSA CONSTRUCTION, RAIPUR

In the result, appeal of the revenue is dismissed

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

253 by the Revenue in the case of PSA construction For the A.Y. 2014-15-- request regarding – Appellant The revenue Partnership firm Assessment year 2014-15- Trading of tractors, trolly and parts ITR us 139 03-09-2014 Rs.77,71,280/- Assessed income 24-12-2016 Rs.3,10,30,484/- us 143(3) Addition Rs.2

KAILASH CHAND AGRAWAL,KORBA vs. DY. COMMISSIONER OF INCOME TAX, KORBA

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकरअपील सं. / Ita No. 274/Rpr/2016 िनधा"रण वष" / Assessment Year : 2008-2009 Kailash Chand Agrawal Prop. Shree Balaji Road Carrier T.P. Nagar, Korba – 495679 (C.G) Pan : Adnpa 6830 G .......अपीलाथ" / Appellant बनाम / V/S. Dy Commissioner Of Income Tax, Korba - 495679 (C.G.) ……""थ" / Respondent Appearances Assessee By : Shri G. S. Agrawal Revenue By : Shri G.N Singh सुनवाई की तारीख / Date Of Conclusive Hearing : 09/02/2022 घोषणा की तारीख / Date Of Pronouncement : 09/02/2022 आदेश/ Order Per Jamlappa D. Battull, Am; Against The First Appellate Order Of Commissioner Of Income Tax - Appeals, Bilaspur [For Short “Cit(A)”] Passed U/S 250 Vide Order Dt 07/03/2016 Which Emanated Out Of An Order Of Rectification [For Short “Ro”] Dt 06/08/2013 For Ay 2008-2009 Passed By The Assessing Officer [For Short “Ao”] U/S 154 Of The

253. 2. The solitary issue under present appeal is that, the appellant assessee challenges the direction of Ld. CIT(A) issued to Ld. AO for initiating remedial action u/s 147 of the Act. 3. Before advancing the matter on facts for adjudication, it is necessary to reproduce ground challenged by the appellant assessee as under; “1. That under the facts

ALANKAR ALLOYS PVT. LTD., KOLKATA,KOLKATA vs. DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita Nos. 428, 429 & 430/Rpr/2025 "नधा"रण वष" / Assessment Years : 2011-12, 2015-16 & 2020-21 Alankar Alloys Private Limited C/O. Subash Agrawal & Associates Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700 069 Pan: Aafca9127J

TDS), Raipur (C.G.), TAX Case No.17/2025, dated 24.02.2025, and (iii) Inder Singh Vs. the State of Madhya Pradesh, Civil Appeal No…………/2025, Special Leave Petition (Civil) No.6145 of 2024, dated 21st March, 2025, we condone the delay of 253, 240 & 88 days, respectively involved in the captioned appeals. 6. At the very outset, it is noted that as per Para

ALANKAR ALLOYS PVT. LTD.,KOLKATA vs. DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita Nos. 428, 429 & 430/Rpr/2025 "नधा"रण वष" / Assessment Years : 2011-12, 2015-16 & 2020-21 Alankar Alloys Private Limited C/O. Subash Agrawal & Associates Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700 069 Pan: Aafca9127J

TDS), Raipur (C.G.), TAX Case No.17/2025, dated 24.02.2025, and (iii) Inder Singh Vs. the State of Madhya Pradesh, Civil Appeal No…………/2025, Special Leave Petition (Civil) No.6145 of 2024, dated 21st March, 2025, we condone the delay of 253, 240 & 88 days, respectively involved in the captioned appeals. 6. At the very outset, it is noted that as per Para

ALANKAR ALLOYS PVT. LTD. , KOLKATA,KOLKATA vs. DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita Nos. 428, 429 & 430/Rpr/2025 "नधा"रण वष" / Assessment Years : 2011-12, 2015-16 & 2020-21 Alankar Alloys Private Limited C/O. Subash Agrawal & Associates Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700 069 Pan: Aafca9127J

TDS), Raipur (C.G.), TAX Case No.17/2025, dated 24.02.2025, and (iii) Inder Singh Vs. the State of Madhya Pradesh, Civil Appeal No…………/2025, Special Leave Petition (Civil) No.6145 of 2024, dated 21st March, 2025, we condone the delay of 253, 240 & 88 days, respectively involved in the captioned appeals. 6. At the very outset, it is noted that as per Para

GRAMIN SEWA SAHAKARI SAMITI, BHENDRI ,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, KODEBOD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, KODEBOD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, BHAKHARA, KURUD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, SANKARDAH,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, KOSMARRA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, SANKARDAH,DHAMTARI vs. INOCME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, MADELI,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

In the result, the appeal of the assessee society in ITA No

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible