ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-I, RAIPUR vs. MESERS CHHATTISGARH STEEL & POWER LIMITED, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

TDS on wheeling charges is not sustainable, hence the disallowance u/s 40 (a)(ia) of the Act is deleted and this ground of appeal is allowed.” We find that the aforesaid view of the CIT(Appeals) is supported by the order of the ITAT, Mumbai in the case of Chhattisgarh State Electricity Board Vs. Income Tax Officer

SOUTH EASTERN COALFIELDS LTD,BILASPUR(CG) vs. DY.. C.I.T.-1(1), BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

THE DY. CIT- CIR.-1(1),, BILASPUR(CG) vs. SOUTH EASTERN COALFILDS LTD.,, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR,BILASPUR(CG) vs. THE DY. COMMISSIONER OF INCOME TAX,CIRCLE , 1(1)BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG) vs. SOUTH EASTERN COAL FIELDS LTD.,, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

SOUTH EASTERN COAL FIELDS LTD.,,BILASPUR(CG) vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

THE DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1)BILASPUR, BILASPUR(CG) vs. THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

31 South Eastern Coalfields Group of cases (On penalty) change in response to what others do, including judges. (for a detailed discussion, see Ward Farnsworth's Legal Analyst: A Toolkit for Thinking about the Law)[ 72]. 175. Kaushalya has adopted an ex-post approach to the issue resolution; Goa Dourado Promotions, an ex-ante approach. Kaushalya saves one single case

DOLPHIN PROMOTERS AND BUILDERS,RAIPUR vs. ADDL.CIT, RANGE-1, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 58/Rpr/2024 (िनधा"रण वष" Assessment Year: 2011-12)

1) or subsection (2) of Section 120, therefore, the provisions of sub- section (3) of Section 124 which places an embargo on an assessee to raise an objection as regards the validity of the jurisdiction of an A.O would get triggered only in a case where the dispute of the assessee is with respect to the territorial jurisdiction and would

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

31 March 2020 passed by the (ld. AO') levying penalty under section 270A of the Act is bad in law and liable to be quashed. 2. That on the facts and in the circumstances of the case, the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre ['Ld. CIT(A), NFAC] erred in mis- interpreting its jurisdiction thereby

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)

1. This is an appeal filed before ITAT on 31-05-2019 by the assessee against adverse appeal order of CIT appeal dated 02-06-2017. The delay in filing of form no 36 is more than 668 days. On issuing letter, the assessee replied on 02-07- 2019 and admitted that, there is delay in filing form

SHRI SHRI SUSHIL KUMAR AGRAWAL, KORBA,KORBA(CG) vs. THE JOINT COMMISSIONER OF INCOME TAX,RANGE KORBA, KORBA(CG)

In the result, appeal of the assesee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 93 & 94/Rpr/2017 "नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Shri Sushil Kumar Agrawal, Prop. Of M/S. Shrikishan & Co., T.P Nagar, Korba (C.G.) Pan : Acgpa4350B .......अपीलाथ"/Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Korba (C.G.) ……""यथ" / Respondent

TDS or under the mistaken belief that the methodology of splitting a single payment into parts below Rs. 20,000/- would provide him escape from the rigour of the provisions of the Act providing for disallowance. In either event, the appellant had not been a bonafide assessee who had made the deduction and deposited it subsequently. Obviously, the appellant could

SHRI SHRI SUSHIL KUMAR AGRAWAL, KORBA,KORBA(CG) vs. THE JOINT COMMISSIONER OF INCOME TAX,RANGE KORBA, KORBA(CG)

In the result, appeal of the assesee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 93 & 94/Rpr/2017 "नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Shri Sushil Kumar Agrawal, Prop. Of M/S. Shrikishan & Co., T.P Nagar, Korba (C.G.) Pan : Acgpa4350B .......अपीलाथ"/Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Korba (C.G.) ……""यथ" / Respondent

TDS or under the mistaken belief that the methodology of splitting a single payment into parts below Rs. 20,000/- would provide him escape from the rigour of the provisions of the Act providing for disallowance. In either event, the appellant had not been a bonafide assessee who had made the deduction and deposited it subsequently. Obviously, the appellant could