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

GRAMIN SEWA SAHAKARI SAMITI (MARYADIT), GAURBHAT,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

Bench: Shri Ravish Sood

TDS on commission received on paddy procurement business, as under: 4 Gramin Sewa Sahakari Samiti Maryadit ITA Nos. 87 to 89 / RPR/2023 Sl. No. Particulars Amount in Rs. 1. Disallowance of the assessee’s claim for Rs.36,222/- deduction of interest income u/s. 80P(2)(a)(i) of the Act. 2. Disallowance of the assessee’s claim for Rs.22

GRAMIN SEWA SAHAKARI SAMITI MARYADIT, CHAMPAJHAR,RAIPUR vs. INCOME TAX OFFICER-1(1), RAIPUR, RAIPUR

Bench: Shri Ravish Sood

TDS on commission received on paddy procurement business, as under: 4 Gramin Sewa Sahakari Samiti Maryadit ITA Nos. 87 to 89 / RPR/2023 Sl. No. Particulars Amount in Rs. 1. Disallowance of the assessee’s claim for Rs.36,222/- deduction of interest income u/s. 80P(2)(a)(i) of the Act. 2. Disallowance of the assessee’s claim for Rs.22

GRAMIN SEWA SAHAKRI SAMITI MARYADIT, DHARSIWA,RAIPUR vs. INCOME TAX OFFICER 1(2), RAIPUR, RAIPUR

Bench: Shri Ravish Sood

TDS on commission received on paddy procurement business, as under: 4 Gramin Sewa Sahakari Samiti Maryadit ITA Nos. 87 to 89 / RPR/2023 Sl. No. Particulars Amount in Rs. 1. Disallowance of the assessee’s claim for Rs.36,222/- deduction of interest income u/s. 80P(2)(a)(i) of the Act. 2. Disallowance of the assessee’s claim for Rs.22

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEWA SAHAKARI SAMITI MARYADIT,VILL: SIRIYADIH, DISTT: BALODABAZAR vs. INCOME TAX OFFICER, BHATAPARA

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEWA SAHAKARI SAMITI MARYADIT,VILL: RISDA, DIST: BALODA BAZAR vs. INCOME TAX OFFICER, BHATAPARA

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEWA SAHAKARI SAMITI MARYADIT, VILLAGE: TAMASEONI,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

THE GRAMIN SEWA SAHAKARI SAMITI MARYADIT,RAIPUR (CG) vs. THE INCOME TAX OFFICER, WARD-1(3),RAIPUR, RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2

GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. INCOME TAX OFFICER , DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Arun Khodpia

TDS on the commission received from paddy procurement business as an expenditure, then, no addition on the said count would be called for in its hands. Thus, the Ground of appeal No.1 (iii) raised by the assessee is allowed for statistical purposes. 16. Adverting to the assessee’s claim for deduction under Sec. 80P(2