KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

Section 50C of the Act were applicable, initiated the proceedings u/s.147 of the Act. As observed by us hereinabove, in the present case of the assessee, the facts, viz. (i) that the assessee owned 10 bogus benami concerns through which accommodation entries were being provided by him to certain beneficiaries was not there before the A.O in the course

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

Section 50C of the Act were applicable, initiated the proceedings u/s.147 of the Act. As observed by us hereinabove, in the present case of the assessee, the facts, viz. (i) that the assessee owned 10 bogus benami concerns through which accommodation entries were being provided by him to certain beneficiaries was not there before the A.O in the course

DCIT(CENTRAL)-1, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

Section 50C of the Act were applicable, initiated the proceedings u/s.147 of the Act. As observed by us hereinabove, in the present case of the assessee, the facts, viz. (i) that the assessee owned 10 bogus benami concerns through which accommodation entries were being provided by him to certain beneficiaries was not there before the A.O in the course

DCIT(CENTRAL)-1,RAIPUR, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

Section 50C of the Act were applicable, initiated the proceedings u/s.147 of the Act. As observed by us hereinabove, in the present case of the assessee, the facts, viz. (i) that the assessee owned 10 bogus benami concerns through which accommodation entries were being provided by him to certain beneficiaries was not there before the A.O in the course

DCIT(CENTRAL)-1, RAIPUR, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

Section 50C of the Act were applicable, initiated the proceedings u/s.147 of the Act. As observed by us hereinabove, in the present case of the assessee, the facts, viz. (i) that the assessee owned 10 bogus benami concerns through which accommodation entries were being provided by him to certain beneficiaries was not there before the A.O in the course

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. SHRI VINAY AGRAWAL, MAHASAMUND

The appeal of the revenue stands dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 29 & 30/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15, 2015-16)

bogus purchases @ 8% which comes to Rs.7,31,000/- (8% of Rs.91,37,500/-) and the extra profit shown by the assessee in the return filed in response to notice u/s 148 for Rs.2,79,600/- was reduced from the aforesaid estimated profit, accordingly, the addition of Rs.4,51,400/- (7,31,000 – 2,79,600) was sustained

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. SHRI VINAY AGRAWAL, MAHASAMUND

The appeal of the revenue stands dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 29 & 30/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15, 2015-16)

bogus purchases @ 8% which comes to Rs.7,31,000/- (8% of Rs.91,37,500/-) and the extra profit shown by the assessee in the return filed in response to notice u/s 148 for Rs.2,79,600/- was reduced from the aforesaid estimated profit, accordingly, the addition of Rs.4,51,400/- (7,31,000 – 2,79,600) was sustained

KAMLESH KUKREJA, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 379/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16)

purchase to the tune of Rs.2,29,87,000/-, from Shri Deepak Nanjyani during FY 2014-15. 4. Based on aforesaid information, notice u/s.148A(b) of the Act was issued to the assessee, in response to which, the assessee had not filed his submissions. Thereafter, an order u/s.148A(d) of the Act was passed on 26.07.2022 and notice u/s.148

KAMLESH KUKREJA, RAIPUR,RAIPUR vs. ITO, WARD-1(1), RAIPUR, RAIPUR

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2016-17 Kamlesh Kukreja Ito, Ward-1(1), Raipur Prop. Anmol Industries, Vs. Surajpura Road, Bhatapara, Raipur – 493118 Ahvpk6618C (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

2: "On the facts and circumstances of the case and in law, approval granted u/s 151 by Pr.CIT dt 6-7-22 is invalid as he was not the specified authority to grant sanction 151(ii) for AY 16-17 under new regime i.e., more than 3 years from the end of the relevant AY; in absence of a valid

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

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

SATISH KUMAR AGRAWAL, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-2(1), BHILAI, DURG

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.145/Rpr/2024 "नधा"रण वष" / Assessment Year : 2018-19 Satish Kumar Agrawal 3B, Heav Industrial Area, Hathkhoj, Bhilai, Dist. Durg-490 026 (C.G.) Pan: Adqpa1785K

2. Gitesh Agrawal (Prop. of ACIPA4087B 1,75,39,352 Bogus sales Abhishek Enterprises) 3. Gitesh Agrawal (Prop. of ACIPA4087B 1,31,07,841 Bogus purchases Abhishek Enterprises) 4. M/s. Mayom Steels Ltd. AAGCM0615C 49,76,860/- Bogus purchases 4 Satish Kumar Agrawal Vs. ITO, Ward-2(1), Bhilai 3. The A.O based on the aforementioned information initiated proceedings u/s.148A

SMT. BASANTI BAI AGRAWAL, MAHASAMUND,MAHASAMUND vs. INCOME TAX OFFICER, WARD-MAHASAMUND, MAHASAMUND

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.259/Rpr/2025 "नधा"रण वष" /Assessment Year : 2016-17 Smt. Basanti Bai Agrawal Proprietor: Shri Narayan Rice Industries, Main Road, Samhar B.O, Samhar, P.O. Bagbahra, Dist.: Mahasamund-493 449 Pan: Acopa8043K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Mahasamund (C.G.) ……""यथ" / Respondent

Purchases were genuine and supported by verifiable documents, yet held as bogus without proper appreciation of evidences produced by the assessee making the addition of Rs.8,04,705/- liable to be deleted. 10. Disallowance of Rs.12,513/- being 20% of vehicle expense is arbitrary and made merely on non-maintenance of logbook without any evidence of personal use is liable

SHREE KRISHNA UDYOG, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

In the result, this appeal of assessee is allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 841/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Shree Krishna Udyog, 17A, Vs Income Tax Officer, Ward 1(1), Bhanpuri Industrial Area, Aaykar Bhawan, Civil Lines, Raipur, Chhattisgarh, 492010 Raipur Chhattisgarh, 492001 Pan: Aapfs5659E (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri G. S. Agrawal, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 16/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

section 250 of the Income Tax Act, 1961 (‘Act’). 2. The appellant assessee has raised following grounds of appeal: - “1. That under the facts and the law, the Order of below authorities are bad in law and on facts. Disallowance of Rs. 53,32,200/- kindly be deleted. 2. That under the facts and the law, the Ld. Commissioner

FIVE STARCONSTRUCTION COMPANY,BHILAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), BHILAI

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.45/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 Five Star Construction Company Plot No.96-97, Light Industrial Area, Chawani Chowk, Bhilai (C.G)-490026 Pan : Aaaff4316L .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Bhilai (C.G.) ……""यथ" / Respondent

2. Disallowance under Sec.40A(3) of the Act out of the 1,04,52,789/- expenditure of Rs.6,33,28,060/- (supra). 3. Disallowance under Sec.40A(3) of the payments 1,66,86,151/- which as per the manual cash book were made by the assessee to a person on a single day in cash exceeding Rs.20,000/- . 4. Disallowance

INCOME TAX OFFICER-1(2), RAIPUR vs. KANHA GRAIN PROCESS, RAIPUR

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

bogus purchases. 4. Before the Ld. CIT(A) / NFAC, the assessee apart from challenging the addition on merit, challenged the validity of re-assessment proceedings. The Ld. CIT(A) / NFAC held that the Additional Solicitor General of India, on behalf of the Revenue agreed that the notice issued for the A.Y. 2015-16, between

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL-1), RAIPUR, RAIPUR vs. M/S SUNIL SPONGE PVT. LTD., RAIPUR

In the result, the appeal of the revenue is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.73/Rpr/2022 "नधा"रण वष" / Assessment Year : 2007-08 The Deputy Commissioner Of Income Tax, (Central Circle)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunil Sponge Pvt. Ltd. H. No.11, Jalvihar Colony, Raipur (C.G.)-492 001 (C.G.) Pan : Aahcs7999A ……""यथ" / Respondent

bogus and hence, there was income escaped from assessment. Allowing the discount/deduction at the year end cannot form reason to believe. The AO had no material to reason to believe that there was income escaped from the assessment. Hon’ble Bombay High Court in the case of Hindustan Liver Limited 268 ITR 332 has held as under: The reason recorded

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.)

Bogus Long term capital gain (LTCG)/Loss. ……. The purchase and sale transactions were carried through registered broker and through demat accounts but the assessee cannot escape from the onus of proving the transaction to be genuine. It is a fact that the assessee has purchased and the sold i.e. traded the scrip of Oasis Tradelink in order to claim

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.)

Bogus Long term capital gain (LTCG)/Loss. ……. The purchase and sale transactions were carried through registered broker and through demat accounts but the assessee cannot escape from the onus of proving the transaction to be genuine. It is a fact that the assessee has purchased and the sold i.e. traded the scrip of Oasis Tradelink in order to claim