DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR vs. S.P. BUILDCON PVT. LTD., RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 35 & 38/Rpr/2023) (Assessment Year: 2014-15 & 2016-17) Deputy Commissioner Of Income Tax, V S.P. Buildcon Private Limited Circle-1(1), S Ff-06, Shyam Plaza, Pandri Bus Stand, Aayakar Bhawan, Civil Lines, Raipur Raipur Pan: Aajcs0653H (अपीलाथ" /Applicant) . (""यथ" / Respondent) . िनधा"रती क" ओर से /Assessee By : Shri Amit M. Jain, Adv. राज"व क" ओर से /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 05-09-2023 घोषणा क" तार"ख/Date Of Pronouncement : 28-11-2023

gains arising before the 1st day of April, 1946, or after the 31st day of March, 1948, and before the 1st day of April, 1956. Explanation 2.—The expression "accumulated profits" in sub- clauses (a), (b), (d) and (e), shall include all profits of the company up to the date of distribution or payment referred to in those sub-clauses

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No.114/Rpr/2022 "नधा"रण वष" / Assessment Year : 2013-14 Gramin Sewa Sahakari Samiti Maryadit Village- Pacheda, Block-Abhanpur, Chhatisgarh-493 661 Pan : Aaaag9886H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Raipur (C.G.) ……""यथ" / Respondent

capital, if not immediately required to be lent to the members, they cannot keep the said amount idle. If they deposit this 14 Gramin Sewa Sahakari Samiti Maryadit Vs. ITO-1(1) amount in bank so as to earn interest, the said interest income is attributable to the profits and gains of the business of providing credit facilities

CHHATTISGARH STATE POWER TRANSMISSION COMPANY LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), RAIPUR

In the result, the appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.81/Rpr/2020 "नधा"रण वष" / Assessment Year : 2011-12 Chhattisgarh State Power Transmission Company Ltd. Executive Director (Fin.), Csptcl, Second Floor, Sldc Building, Cseb Office Campus, Danginiya Raipur-492 013 (C.G.) Pan : Aadcc5773E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-4(1), Raipur (C.G.) ……""यथ" / Respondent

d), clause (e) and clause (f) which is consequential in nature. It is also proposed to omit the second proviso to the said section. These amendments will take effect from 1st April, 2004 and will, accordingly, apply in relation to the assessment year 2004-2005 and subsequent years." 42. The rationale for introduction of Section 43B was explained by this

CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-4(1), RAIPUR

In the result, the appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.81/Rpr/2020 "नधा"रण वष" / Assessment Year : 2011-12 Chhattisgarh State Power Transmission Company Ltd. Executive Director (Fin.), Csptcl, Second Floor, Sldc Building, Cseb Office Campus, Danginiya Raipur-492 013 (C.G.) Pan : Aadcc5773E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-4(1), Raipur (C.G.) ……""यथ" / Respondent

d), clause (e) and clause (f) which is consequential in nature. It is also proposed to omit the second proviso to the said section. These amendments will take effect from 1st April, 2004 and will, accordingly, apply in relation to the assessment year 2004-2005 and subsequent years." 42. The rationale for introduction of Section 43B was explained by this

THE SEWA SAHAKARI SAMITIT MARYADIT,RAMPUR,RAJNANDGAON vs. THE INCOME TAX OFFICER-1, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE SEWA SAHAKARI SAMITIT MARYADIT,SINGHOLA,RAJNANDGAON vs. THE INCOME TAX OFFICER-1, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

HE SEWA SAHAKARI SAMITIT MARYADIT, SURGI,RAJNANDGAON vs. THE INCOME TAX OFFICER-2, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

M/S GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. THE INCOME TAX OFFICER, DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE SEWA SAHAKARI SAMITIT MARYADIT,JOSHILAMATI,RAJNANDGAON vs. THE INCOME TAX OFFICER -1,, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. THE INCOME TAX OFFICER, DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,RAIPUR (CG) vs. THE INCOME TAX OFFICER 1(3), RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,RAIPUR (CG) vs. THE INCOME TAX OFFICER 1(3), RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE SEWA SAHAKARI SAMITIT MARYADIT,GHATULA,RAJNANDGAON vs. THE INCOME TAX OFFICER-2, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. THE INCOME TAX OFFICER, DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE SEWA SAHAKARI SAMITIT MARYADIT,SOMNI,RAJNANDGAON vs. THE INCOME TAX OFFICER-2, RAJNANDGAON

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,RAIPUR vs. THE INCOME TAX OFFICER 1(3), RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,RAIPUR (CG) vs. THE INCOME TAX OFFICER 1(3), RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,DHAMTARI(C.G) vs. THE INCOME TAX OFFICER, DHAMTARI, DHAMTARI(C.G)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court

THE GRAMIN SEVA SAHAKARI SAMITI MARYADIT,BALODA BAZAR(C.G0 vs. THE INCOME TAX OFFICER 1(3), RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

capital which was not immediately required, and was deposited in bank so as to earn interest income would be attributable to the profit and gains of its business of providing credit facilities to its members and thus, would be eligible for deduction u/s. 80P of the Act. It was submitted by the Ld. AR that the Hon’ble High Court