JANTA INDUSTRIES,BASPAIPARA vs. MS.RANJINI SRIKUMAR, INCOME TAX OFFICER(TDS), INCOME TAX OFFICE

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita Nos.46 & 47/Rpr/2026 "नधा"रण वष" / Assessment Year : 2013-14 Janta Industries Durga Talkies Road, Rajnandgaon (C.G.)-491 441 Pan: Aaffj9101J ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer (Tds) Centralized Processing Centre (Cpc) Bengaluru ……""यथ" / Respondent

3 Janta Industries Vs. ITO (TDS)/CPC, Bengaluru ITA Nos. 46 & 47/RPR/2026 6. We have heard the submissions of the Ld. Sr. DR and considered the written submissions filed by the assessee. We find that this issue had come up for adjudication before the Raipur Bench in a series of cases of Chhattisgarh Gramin Bank Vs. Income Tax Officer (TDS

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

In the result, appeal of the assessee company is allowed for statistical purposes in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 43/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

section 3 M/s. South Eastern Coalfields LimitedVs. ACIT, Circle-1(1), Bilaspur 246A(1)(q) of the Act, thereby making the proceedings liable to be quashed. 3 That, on the facts and in the circumstances of the case and in law, the Ld. AO erred in issuing show cause notice require appearance on a public holiday which renders the penalty

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

TDS), Raipur (C.G.), TAX Case No.17/2025, dated 24.02.2025 and (iv) Inder Singh Vs. the State of Madhya Pradesh, Civil Appeal No…………/2025, Special Leave Petition (Civil) No.6145 of 2024, dated 21st March, 2025, the said delay of 58 days involved in the present appeal is condoned. 5. In this case, the assessee has filed both legal grounds as well

BLOCK RESOURCES COORDINATOR RAJIV GANDHI SIKSHA MISSION,PATAN vs. INCOME TAX OFFICER, TDS, BHILAI

In the result, grounds raised in all these three appeals are partly allowed for statistical purposes

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.33, 34 & 35/Rpr/2020 िनधा"रण वष" /Assessment Years: 2011-12 & 2012-13 V. Block Resources Coordinator Ito (Tds) Rajiv Gandhi Siksha Mission, Block Bhilai Patan, Bathena Road, Patan Dist. Durg – 491 111 Chhattisgarh

Section 201(1) be computed @ 1% as provided u/s 194C as PAN of the said deductee is available, the Learned AO has further erred in not giving credit of Rs. 1, 571/- which has been paid by the assessee merely due to the reason that the same could not be mentioned in the quarterly TDS Statement u/s 200(3

BLOCK RESOURCES COORDINATOR RAJIV GANDHI SIKSHA MISSION,PATAN vs. INCOME TAX OFFICER, TDS, BHILAI

In the result, grounds raised in all these three appeals are partly allowed for statistical purposes

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.33, 34 & 35/Rpr/2020 िनधा"रण वष" /Assessment Years: 2011-12 & 2012-13 V. Block Resources Coordinator Ito (Tds) Rajiv Gandhi Siksha Mission, Block Bhilai Patan, Bathena Road, Patan Dist. Durg – 491 111 Chhattisgarh

Section 201(1) be computed @ 1% as provided u/s 194C as PAN of the said deductee is available, the Learned AO has further erred in not giving credit of Rs. 1, 571/- which has been paid by the assessee merely due to the reason that the same could not be mentioned in the quarterly TDS Statement u/s 200(3

BLOCK RESOURCES CENTRE RAJIV GSANDHI SIKSHA MISSION,DHAMDHA vs. INCOME TAX OFFICER, TDS, BHILAI

In the result, grounds raised in all these three appeals are partly allowed for statistical purposes

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.33, 34 & 35/Rpr/2020 िनधा"रण वष" /Assessment Years: 2011-12 & 2012-13 V. Block Resources Coordinator Ito (Tds) Rajiv Gandhi Siksha Mission, Block Bhilai Patan, Bathena Road, Patan Dist. Durg – 491 111 Chhattisgarh

Section 201(1) be computed @ 1% as provided u/s 194C as PAN of the said deductee is available, the Learned AO has further erred in not giving credit of Rs. 1, 571/- which has been paid by the assessee merely due to the reason that the same could not be mentioned in the quarterly TDS Statement u/s 200(3

MICKEY SHRIVASTVA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX -3(1), RAIPUR

In the result, appeal of the assessee is allowed

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

3 & 4 of AO orders, where he has violated various provisions of section XVII B by not deducting and depositing TDS

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

3. The Ld. CIT (A) erred in law and in facts in confirming the action of the CPC for making adjustment on the basis of information available in the Form 26AS related to TDS u/s.194DA as the provisions of Section

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

3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion of Section 271H providing for penal provision for such failure to submit return. When the Parliament has simultaneously brought about Section 5 Padma Parakh Vs. ITO (TDS

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

3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion of Section 271H providing for penal provision for such failure to submit return. When the Parliament has simultaneously brought about Section 5 Padma Parakh Vs. ITO (TDS

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

3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion of Section 271H providing for penal provision for such failure to submit return. When the Parliament has simultaneously brought about Section 5 Padma Parakh Vs. ITO (TDS

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 and the Hon'ble bench decided that n issue, which raises a question of fact and can be done only on scrutiny ssessment u/s. 143(3) of the Act or by reopening of assessment u/s. 147 of the Act. 1.4 It is an established legal position that an addition made by the CPC under Section

NISHANT JAIN,BILASPUR vs. ACIT CENTRAL CIRCLE, BILASPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 510, 511 & 512/Rpr/2024 "नधा"रण वष" / Assessment Years : 2014-15, 2017-18 & 2018-19 Nishant Jain Ring Road No.2, Shanti Nagar, Near Sidhasikhar Vistar, Bilaspur (C.G.)-495 001 Pan: Agepj9793M .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

TDS. The payment may be for work done or mobilization advance or for advance for machinery purchase. They don't differentiate between the payment of gross receipts of advance made for machinery or mobilization advance. That during the year under consideration Rs.1,56,87,000/- amount has been received against mobilization advances and machinery advances from Executive Engineer Chhattisgarh Rural

NISHANT JAIN,BILASPUR vs. ACIT CIRCLE 1(1), BILASPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 510, 511 & 512/Rpr/2024 "नधा"रण वष" / Assessment Years : 2014-15, 2017-18 & 2018-19 Nishant Jain Ring Road No.2, Shanti Nagar, Near Sidhasikhar Vistar, Bilaspur (C.G.)-495 001 Pan: Agepj9793M .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

TDS. The payment may be for work done or mobilization advance or for advance for machinery purchase. They don't differentiate between the payment of gross receipts of advance made for machinery or mobilization advance. That during the year under consideration Rs.1,56,87,000/- amount has been received against mobilization advances and machinery advances from Executive Engineer Chhattisgarh Rural

NISHANT JAIN,BILASPUR vs. ACIT CIRCLE 1(1), BILASPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 510, 511 & 512/Rpr/2024 "नधा"रण वष" / Assessment Years : 2014-15, 2017-18 & 2018-19 Nishant Jain Ring Road No.2, Shanti Nagar, Near Sidhasikhar Vistar, Bilaspur (C.G.)-495 001 Pan: Agepj9793M .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

TDS. The payment may be for work done or mobilization advance or for advance for machinery purchase. They don't differentiate between the payment of gross receipts of advance made for machinery or mobilization advance. That during the year under consideration Rs.1,56,87,000/- amount has been received against mobilization advances and machinery advances from Executive Engineer Chhattisgarh Rural

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3): Thus 206(6) clearly provides that any person responsible for collecting the tax, even if he fails to collect the tax in accordance with the provisions of the said section, shall not withstanding such failure, be liable to pay the tax to the credit of the Central Government. In such a case of failure, this section fixes the liability

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3): Thus 206(6) clearly provides that any person responsible for collecting the tax, even if he fails to collect the tax in accordance with the provisions of the said section, shall not withstanding such failure, be liable to pay the tax to the credit of the Central Government. In such a case of failure, this section fixes the liability

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3): Thus 206(6) clearly provides that any person responsible for collecting the tax, even if he fails to collect the tax in accordance with the provisions of the said section, shall not withstanding such failure, be liable to pay the tax to the credit of the Central Government. In such a case of failure, this section fixes the liability