INCOME TAX OFFICER-1(1), BILASPUR vs. MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD. , BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

purchase price as per section 50C of the Act, by applying a 10% tolerance limit retrospectively, and further erred in holding that the correct provision applicable was section 56(2)(vii)(b) of the Act instead of section 69, despite the fact that section 56(2)(vii)(b) is applicable only to individuals and Hindu Undivided Families (HUFs) for Assessment

DY. COMMISSIONER OF INCOME TAX-1(1), BHILAI vs. NIKHIL MITTAL, BHILAI

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.656/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 The Deputy Commissioner Of Income Tax-1(1), Bhilai (C.G.)

search and seizure action was conducted u/s. 132 of the Income Tax Act, 1961 (for short ‘the Act’) in the case of Hanumant Trading and H.K Group on 19.02.2020. In his statement recorded on oath, Shri Mithilesh Kumar Tiwari, proprietor of M/s. H.K Enterprises has provided accommodation entries of bogus purchases

AGRAWAL INFRABUILD PRIVATE LIMITED ,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, RAIPUR

In the result, both appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.10 & 11/Rpr/2020 (ननधाारण वषा / Assessment Year :2013-2014 & 2014-2015) Agrawal Infrabuild Private Limited, Vs Acit, Central Circle-Ii, Raipur 1St Floor, V.R.Plaza, Bilaspur Pan No. :Aafca 6636 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

bogus share application money u/s 68. The addition made by the A.O. and confirmed by by Ld CIT-A, were unjustified, unwarranted and uncalled for. 9. In continuation, Ld AR further drew our attention to the submission of the assessee before the Ld AO during the post search assessment proceedings submitted on 13.11.2018, the same is extracted as under

AGRAWAL INFRABUILD PRIVATE LIMITED ,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, RAIPUR

In the result, both appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.10 & 11/Rpr/2020 (ननधाारण वषा / Assessment Year :2013-2014 & 2014-2015) Agrawal Infrabuild Private Limited, Vs Acit, Central Circle-Ii, Raipur 1St Floor, V.R.Plaza, Bilaspur Pan No. :Aafca 6636 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

bogus share application money u/s 68. The addition made by the A.O. and confirmed by by Ld CIT-A, were unjustified, unwarranted and uncalled for. 9. In continuation, Ld AR further drew our attention to the submission of the assessee before the Ld AO during the post search assessment proceedings submitted on 13.11.2018, the same is extracted as under

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / It(Ss)A No. 14 & Ita Nos. 513, 514, 515, 516 & 517/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18, 2014-15, 2015-16, 2016-17, 2018-19 & 2019-20)

seizure proceedings and post search investigation, the GP rate @5% on unaccounted sale and purchase was offered by the assessee company, but not acceptable. Therefore, the rate of GP is taken at 8% on the total unaccounted sale of the assessee and the same is treated as unaccounted income of the assessee for respective assessment years, as under

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / It(Ss)A No. 14 & Ita Nos. 513, 514, 515, 516 & 517/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18, 2014-15, 2015-16, 2016-17, 2018-19 & 2019-20)

seizure proceedings and post search investigation, the GP rate @5% on unaccounted sale and purchase was offered by the assessee company, but not acceptable. Therefore, the rate of GP is taken at 8% on the total unaccounted sale of the assessee and the same is treated as unaccounted income of the assessee for respective assessment years, as under

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / It(Ss)A No. 14 & Ita Nos. 513, 514, 515, 516 & 517/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18, 2014-15, 2015-16, 2016-17, 2018-19 & 2019-20)

seizure proceedings and post search investigation, the GP rate @5% on unaccounted sale and purchase was offered by the assessee company, but not acceptable. Therefore, the rate of GP is taken at 8% on the total unaccounted sale of the assessee and the same is treated as unaccounted income of the assessee for respective assessment years, as under

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / It(Ss)A No. 14 & Ita Nos. 513, 514, 515, 516 & 517/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18, 2014-15, 2015-16, 2016-17, 2018-19 & 2019-20)

seizure proceedings and post search investigation, the GP rate @5% on unaccounted sale and purchase was offered by the assessee company, but not acceptable. Therefore, the rate of GP is taken at 8% on the total unaccounted sale of the assessee and the same is treated as unaccounted income of the assessee for respective assessment years, as under

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / It(Ss)A No. 14 & Ita Nos. 513, 514, 515, 516 & 517/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18, 2014-15, 2015-16, 2016-17, 2018-19 & 2019-20)

seizure proceedings and post search investigation, the GP rate @5% on unaccounted sale and purchase was offered by the assessee company, but not acceptable. Therefore, the rate of GP is taken at 8% on the total unaccounted sale of the assessee and the same is treated as unaccounted income of the assessee for respective assessment years, as under

ANIL KUMAR JAIN,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.584 & 585/Rpr/2025 "नधा"रण वष" /Assessment Years : 2018-19 & 2019-20 Anil Kumar Jain 34, Maruti Life Style, Ravi Shankar University, S.O, Raipur-492 010 Pan: Ahypj7657H .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax (Central), Bilaspur (C.G.)

search and seizure operation u/s. 3 Anil Kumar Jain Vs. ACIT (Central), Bilaspur ITA Nos.584 & 585/RPR/2025 132 of the Act was conducted on the residential/business premises of the assessee on 19.02.2020. In response to the notice u/s.153A of the Act, the assessee filed return of income declaring income at Rs.8,13,000/-. That in response to the statutory notices issued

ANIL KUMAR JAIN,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.584 & 585/Rpr/2025 "नधा"रण वष" /Assessment Years : 2018-19 & 2019-20 Anil Kumar Jain 34, Maruti Life Style, Ravi Shankar University, S.O, Raipur-492 010 Pan: Ahypj7657H .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax (Central), Bilaspur (C.G.)

search and seizure operation u/s. 3 Anil Kumar Jain Vs. ACIT (Central), Bilaspur ITA Nos.584 & 585/RPR/2025 132 of the Act was conducted on the residential/business premises of the assessee on 19.02.2020. In response to the notice u/s.153A of the Act, the assessee filed return of income declaring income at Rs.8,13,000/-. That in response to the statutory notices issued

INCOME TAX OFFICER, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

search and seizure action, several incriminating documents, communications and digital data has been found, which led to unearth the operations of the syndicate, establishing clearly the modus operandi of providing Bogus Long term capital gain (LTCG)/Loss and rigging the prices of various scrips on stock exchange for providing Bogus Long term capital gain (LTCG)/Loss. ……. The purchase

INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

search and seizure action, several incriminating documents, communications and digital data has been found, which led to unearth the operations of the syndicate, establishing clearly the modus operandi of providing Bogus Long term capital gain (LTCG)/Loss and rigging the prices of various scrips on stock exchange for providing Bogus Long term capital gain (LTCG)/Loss. ……. The purchase

HANUMANT INGOTS PVT. LTD., RAIPUR,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Accordingly the same is also allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 346 & 347/Rpr/2025 (िनधा"रण वष"Assessment Year: 2013-14 & 2014-15)

Search & Seizure action u/s 132 was conducted in the case of Sarthak Group, Raipur dated 26.11.2019, whereas the case of assessee was covered under survey u/s 133A of the Act, dated 19.01.2019. In the investigation made by ADIT (Inv.-4)-1, Kolkata in the case of M/s Surakshit Real Estate Ltd. (PAN: AANCS3044G), it is found that the assessee company

HANUMANT INGOTS PVT. LTD., RAIPUR,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Accordingly the same is also allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 346 & 347/Rpr/2025 (िनधा"रण वष"Assessment Year: 2013-14 & 2014-15)

Search & Seizure action u/s 132 was conducted in the case of Sarthak Group, Raipur dated 26.11.2019, whereas the case of assessee was covered under survey u/s 133A of the Act, dated 19.01.2019. In the investigation made by ADIT (Inv.-4)-1, Kolkata in the case of M/s Surakshit Real Estate Ltd. (PAN: AANCS3044G), it is found that the assessee company

INCOME TAX OFFICER, WARD 2(1), RAIPUR vs. MESERS ARYAN BUILDERS AND DEVELOPERS PRIVATE LIMITED, RAIPUR

In the result, both appeal of the revenue and cross objection of the assessee stand dismissed in terms of our observations

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

purchased during the year have been classified as Inventory. The AO found that there were receipts of share capital and share premium to the tune of Rs.4,06,000/- and Rs.3,02,941,000/- respectively from various shareholders. The information was sought from the shareholders u/s.133(6) of the Act with a view to conduct enquiry into the genuineness