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.

section 56(2)(vii) (b) of the Act. 10.3. In appellate proceedings the appellant has contested the addition made by the AO by presetting a variety of arguments and relying on a wide range of case laws. It is to be noted here that the AO made a convincing case that the subject land was not a stock in trade

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

56,831 Accordingly, on the basis of his aforesaid deliberations the A.O vide his order passed u/s.143(3) dated 28.03.2014 scaled down the loss of the assessee company to an amount of Rs.(-)2,25,58,748/-. 7. Aggrieved the assessee assailed the order passed by the A.O u/s.143(3) dated 28.03.2014 before the CIT(Appeals), but without any success

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

56,831 Accordingly, on the basis of his aforesaid deliberations the A.O vide his order passed u/s.143(3) dated 28.03.2014 scaled down the loss of the assessee company to an amount of Rs.(-)2,25,58,748/-. 7. Aggrieved the assessee assailed the order passed by the A.O u/s.143(3) dated 28.03.2014 before the CIT(Appeals), but without any success

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)

vii)** ** ** the whole of the amount of profits and gains of business attributable to any one or more of such activities." 7. The word 'attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions

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)

vii)** ** ** the whole of the amount of profits and gains of business attributable to any one or more of such activities." 7. The word 'attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions

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)

vii)** ** ** the whole of the amount of profits and gains of business attributable to any one or more of such activities." 7. The word 'attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions

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)

vii)** ** ** the whole of the amount of profits and gains of business attributable to any one or more of such activities." 7. The word 'attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word 'attributable' as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider 13 Gramin Sewa Sahakari Samiti Maryadit Vs. ITO-1(1) the meaning of the word ‘attributable

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battull

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions

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

vii) xxx the whole of the amount of profits and gains of business attributable to any one or more of such activities.” 7. The word ‘attributable used in the said section is of great importance. The Apex Court had an occasion to consider the meaning of the word ‘attributable’ as supposed to derive from its use in various other provisions