M/S M/S GOYAL CONSTRUCTION COMPANY, RAIPUR,RAIPUR (CG) vs. THE INCOME TAX OFFICER, 3(1),RAIPUR, RAIPUR (CG)

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 17/Rpr/2017 "नधा"रण वष" / Assessment Year : 2012-13 M/S. Goyal Construction Company Shop No.213-214, Ii Floor, Crystal Arcade, Lodhipara Chowk, Raipur (C.G.) Pan : Aaffg9964N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-3(1), Raipur (C.G.). ……""यथ" / Respondent

Income from house property and/or, (c) profits and gains of business or profession and/or; (d) Capital gain and/or (e) income

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

income of members of beneficiaries in the form of exempt capital gain or short-term capital loss. 7.3. As per the information available in public domain, the earning per share (EPS) of the company was negligible. The net worth of the company was also negligible. Even though the net worth of the company and the business

DCIT-1(1), BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

income of members of beneficiaries in the form of exempt capital gain or short-term capital loss. 7.3. As per the information available in public domain, the earning per share (EPS) of the company was negligible. The net worth of the company was also negligible. Even though the net worth of the company and the business

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

income of members of beneficiaries in the form of exempt capital gain or short-term capital loss. 7.3. As per the information available in public domain, the earning per share (EPS) of the company was negligible. The net worth of the company was also negligible. Even though the net worth of the company and the business

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) ..

capital gains and income from other sources. Apart from the said incomes, the Assessee also had Income under the head business

M/S SMS SHIVNATH INFRASTRUCTURE PVT LTD,DURG(CG) vs. THE PR. COMMISSIONER OF INCOME TAX-2, RAIPUR (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) ..

capital gains and income from other sources. Apart from the said incomes, the Assessee also had Income under the head business

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR vs. CHHATTISGARH RAJYA SAHAKARI AWAS SANGH (MARYADIT), 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. 206/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Chhattisgarh Rajya Sahkari Awas Sangh Maryadit C-191, Tagore Nagar, Raipur (C.G.) Pan : Aaaac5903F ……""यथ" / Respondent

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

CHHATTISGARH SAHAKARI SAKH SAMITI MARYADIT, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-1(2), BHILAI, DURG

In the result, appeals filed by the assessee in ITA No 284, 286 &

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.284,285,286,287/Rpr/2023) (Assessment Year:2013-14,2017-18,2018-19,2020-21)

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

CHHATTISGARH SAHAKARI SAKH SAMITI MARYADIT, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-1(2), BHILAI, DURG

In the result, appeals filed by the assessee in ITA No 284, 286 &

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.284,285,286,287/Rpr/2023) (Assessment Year:2013-14,2017-18,2018-19,2020-21)

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

CHHATTISGARH SAHAKARI SAKH SAMITI MARYADIT, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-1(2), BHILAI, DURG

In the result, appeals filed by the assessee in ITA No 284, 286 &

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.284,285,286,287/Rpr/2023) (Assessment Year:2013-14,2017-18,2018-19,2020-21)

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

CHHATTISGARH SAHAKARI SAKH SAMITI MARYADIT, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-1(2), BHILAI, DURG

In the result, appeals filed by the assessee in ITA No 284, 286 &

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.284,285,286,287/Rpr/2023) (Assessment Year:2013-14,2017-18,2018-19,2020-21)

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

SEWA SAHAKARI SAMITI LATABOD,LATABOD vs. INCOME TAX OFFICER, RISALI

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.5/Rpr/2026 "नधा"रण वष" /Assessment Year : 2016-17 Sewa Sahakari Samiti Latabod K-6, Anupam Nagar, Raipur (C.G.) Pan: Aahas1552M

business from such activities and the interest income so derived or the capital, if not immediately required to be lent to the members, instead of keeping the said amount idle, they deposit the amount in bank so to earn interest and the said interest income is attributable to the profits and gains

AARTI SPONGE AND POWER LTD.,RAIPUR vs. PR. COMMISSIONER OF INCOME TAX, RAIPUR - 1, RAIPUR

In the result, appeal of the assessee stands dismissed

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

business loss which would be adjusted against capital gain income u/s 71(2) and the total income in both the cases

SEWA SAHAKARI SAMITI SIRRI, ,BALOD vs. INCOME TAX OFFICER, WARD-1(3), BHILAI, BHILAI

In the result, the appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.109/Rpr/2026 िनधा"रण वष" /Assessment Year: 2016-17 Sewa Sahkari Samiti Sirri, Village & Post:Sirri, Tehsil Gunderdehi, District Balod, Chhattsigarh, 491221 Pan: Aagas8961H .......अपीलाथ" / Appellant बनाम / V/S.

business from such activities and the interest income so derived or the capital, if not immediately required to be lent to the members, instead of keeping the said amount idle, they deposit the amount in bank so to earn interest and the said interest income is attributable to the profits and gains

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

Bench: Shri Ravish Sood

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

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

Bench: Shri Ravish Sood

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

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

Bench: Shri Ravish Sood

business by providing credit facilities to its members. The interest income so derived or the capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this amount in bank so as to earn interest, the said interest income is attributable to the profits and gains

RAHUL BAJPAI,IDGAH CHOWK vs. ACIT CIRCLE 1(1), SHRI RAM PLAZA

In the result, appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.348/Rpr/2023 "नधा"रण वष" / Assessment Year: 2014-15 Rahul Bajpai Idgah Chowk, Bilaspur Chhattisgarh-495 001 Pan: Aexpb4410L .......अपीलाथ" / Appellant बनाम / V/S.

business in real estate was carried out by the appellant as he failed to produce any evidence in support same. Hence, subject land was treated as capital asset and difference between purchase price and stamp duty value was added as income of the appellant in accordance with provisions of section 56(2)(vii) (b) of the Act. 10.3. In appellate