BUNDELAS SECURITAS AND CONSULTANTS PVT. LTD., BILASPUR,BILASPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), BILASPUR, BILASPUR

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 59 & 60/Rpr/2023 "नधा"रण वष" / Assessment Years : 2018-19 Bundelas Securities & Consultants Pvt. Ltd. L-38, Yadunandan Nagar, Tifra, Bilaspur (C.G.)-495 223 Pan : Aaccb6831H .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-2(1), Bilaspur (C.G.) ……""यथ" / Respondent

condone the delay involved in filing of the present appeals by the assessee appellant. 9. Apropos the disallowance of the assessee’s claim for deduction of the delayed deposit of the employee’s share of contribution of Rs.1,44,91,662/- towards, viz. (i). ESI: Rs.17,35,445/-; and (ii). PF: Rs.1,27,56,216/- (wrongly mentioned by the assessee

SATPAL SINGH SANDHU,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 04/Rpr/2023 "नधा"रण वष" / Assessment Year : 2019-20 Satpal Singh Sandhu 151/2, Ward -1, Sandhu Bhavan, Guru Govind Singh Marg, Heerapur, Raipur (C.G.)-492 001 Pan : Cseps7315E .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.). ……""यथ" / Respondent

condoning the delay of 41 days involved in filing of the present appeal. 3. Succinctly stated, the assessee who is a labour contractor had e-filed his return of income for A.Y.2019-20 on 05.11.2019, declaring an income of Rs.24,12,846/-. The return of income filed by the assessee was processed u/s.143(1) of the Act, wherein after making

MARUTI CLEAN COAL AND POWER LTD.,RAIPUR vs. PR. COMMISIONER INCOME TAX-1, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 55/Rpr/2021 "नधा"रण वष" / Assessment Year : 2011-12 Maruti Clean Coal & Power Ltd. Ward No.42, Building No.14, Civil Lines, Near Income Tax Colony, Chhattisgarh-492 001. Pan : Aadcm4810C .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent Assessee By :Shri Salil Kapoor, Ms. Ananya Kapoor & Ms. Soumya Singh, Advocates. Revenue By :Shri P. K Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 05.08.2022 घोषणा क" तार"ख / Date Of Pronouncement : 31.10.2022

condonation of the impugned delay involved in filing of the present appeal by the assessee appellant. 2.2 We have given a thoughtful consideration and considering the circumstances leading to the impugned delay involved in filing of the present appeal r.w the aforesaid order of the Hon’ble Apex Court admit the same. 3. We shall first deal with the additional

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

delay of 58 days involved in the present appeal is condoned. 5. In this case, the assessee has filed both legal grounds as well as grounds on merits. The Ld. Counsel for the assessee submitted that he would assail the legal ground first and if the said legal ground is answered affirmative, then the grounds on merits shall become academic

DOLPHIN PROMOTERS AND BUILDERS,RAIPUR vs. ADDL.CIT, RANGE-1, RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 58/Rpr/2024 (िनधा"रण वष" Assessment Year: 2011-12)

condoned the delay involved in present case. 10. At the threshold of the hearing, Ld. AR pressed following additional grounds: Additional Ground No. 1 dated 04.04.2024 On the facts and circumstances of the case and in law, assessment made u/s 144 by Addl. CIT is invalid as he was not having valid jurisdiction over the assessee firm for making assessment

SHRI GUNJAN KUMAR BIHANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3 (4), RAIPUR, RAIPUR

In the result, the captioned appeal filed by the assessee is allowed in terms of the aforesaid observations

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.122/Rpr/2025 "नधा"रण वष" / Assessment Year : 2015-16 Shri Gunjan Kumar Bihani Ashoka Ratan, Khamhardih, Shankar Nagar, Raipur-492 009 (C.G) Pan: Ajupb5787C

148 for the making of the return or by notice under the first proviso to section 115WF or under the first proviso to section 144 to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier.” In view of the above fact, the assessee has no right

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(1), RAIPUR vs. MESERSS CHHATTISGARH STATEELECTRICITY BOARD, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.31/Rpr/2020 "नधा"रण वष" / Assessment Year : 2006-07 The Deputy Commissioner Of Income Tax, Circle-4(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh State Electricity Board (Through Chhattisgarh State Power Holding Company Limited) Dangania Raipur Pan : Aabcc7876Q ……""यथ" / Respondent

condoned. 23. Admittedly, the appeal filed by the Revenue involves a delay of 3966 days, which, as stated by the Ld. A.R and, rightly so, is an inordinate delay. 29 DCIT, Circle-4(1), Raipur Vs. M/s. Chhattisgarh State Electricity Board Considering that the Revenue had delayed filing the present appeal before us, i.e., filed the appeal after the lapse

VINOD KUMAR KAILASHCHANDRA VERMA, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(3), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 69/Rpr/2026 (िनधा"रण वष" Assessment Year: 2015-16) Vinod Kumar Khailashchandra Verma, Vs Income Tax Officer, Ward 3(1), House No.496/9, Avanti Vihar, Sector-2, Central Revenue Building, Telibandha, Raipur-492001 (C.G.) Civil Lines, Raipur, C.G. 492001 Pan: Aanpv5964B (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. (Adjournment Petition Filed.) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख / Date Of : 06/03/2026 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, on the facts and in law, the Ld. CIT(A), NFAC, Delhi erred in dismissing the appeal in-limine, refusing to condone the delay, without appreciating the facts of the case and provisions of relevant law, and 1 Vinod

ARUNA TIWARI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 90/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Aruna Tiwari 762, Sundar Nagar, Raipur (C.G.)-492 001 Pan: Adbpt4977B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent

delay is found to be covered by the order of the Hon’ble Supreme Court of India in Suo Moto Writ Petition (Civil) No.3 of 2020 dated 23.03.2020, which was thereafter modified vide further order(s) dated 08.03.2021, 27.04.2021, 23.09.2021 and 10.01.2022, as per which for the purpose of limitation the period from 15.03.2020 to 28.02.2022 was to be excluded

RAMAN VASU THACHISARIL, KOLLAM, KOLLAM vs. ITO, WARD- JAGDALPUR, JAGDALPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.91/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Raman Vasu Thachisaril Ramanalayam Clappana, Kollam, Amrithapuri S.O-690 546 Kerala, India Pan: Adopt0795N

condone the delay of 396 days and proceed to hear the matter on merits. 4. The contention in law as assailed by the Ld. Counsel for the assessee through the Ground of appeal No.2 that though assessment has been completed u/s.147/143(3) of the Income Tax Act, 1961 (for short ‘the Act’), however, no valid notice u/s.148

RAJU JHANGHEL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 148 of the Act. The reason for re-opening of these cases were that the appellant assessee had taken accommodation entries aggregating to Rs.16,54,79,650/- and Rs.31,64,15,869/- in AYs 2014-15 and 2015-16 respectively. Consequential, assessments were completed by taxing the above mentioned accommodation entries, which resulted assessments at Rs.16

RAJU JHANGHEL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 148 of the Act. The reason for re-opening of these cases were that the appellant assessee had taken accommodation entries aggregating to Rs.16,54,79,650/- and Rs.31,64,15,869/- in AYs 2014-15 and 2015-16 respectively. Consequential, assessments were completed by taxing the above mentioned accommodation entries, which resulted assessments at Rs.16

KAMLESH SHARMA, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 70/Rpr/2026 (िनधा"रण वष" Assessment Year: 2020-21) Kamlesh Sharma, House No.109, Vs Deputy Commissioner Of Income Harihant Nagar, Sarona, Tax, Circle-1(1), Central Revenue Ring Road No.1, Raipur-492001, Cg Building, Civil Lines, Raipur-492001 Pan: Bppps4514C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None (Adjournment Petition Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख / Date Of : 06/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2020-21 Filed By The Assessee Is Directed Against The Order Dated 18.12.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

section 250 of the Income Tax Act, 1961 (‘Act’). 2. The grounds of appeal raised by the assessee are as under: “1. That, on the facts and in law, the Ld. CIT(A), NFAC, Delhi erred in dismissing the appeal in-limine, refusing to condone the delay, without appreciating the 1 Kamlesh Sharma vs. DCIT, Circle-1(1) facts

MANOJ KUMAR SAHU, DURG,DURG vs. ITO, WARD-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.475/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Manoj Kumar Sahu 151, Village: Rajpur, Tehsil: Dhamdha, Dist. Durg-491 331 (C.G.) Pan: Eomps2921J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Bhilai (C.G.) ……""यथ" / Respondent

delay of 244 days involved in filing the present penalty appeal is condoned after taking guidance from the following judicial pronouncements viz. (i) Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur, Civil Appeal Nos……………../2025 [Special Leave Petition (Civil) Nos. 26310-26311/2024, dated 31.01.2025, (ii) Jagdish Prasad Singhania Vs. Additional Commissioner of Income Tax (TDS), Raipur (C.G.), TAX Case

SAVITA SANJAY MARGHADE,DURG, CHHATTISGARH vs. INCOME TAX OFFICER, BHILAI

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 849/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14) Savita Sanjay Marghade, Mig-658, Vs Income Tax Officer, Aaykar Bhavan, Padmanabhpur, Durg, Chhattisgarh. Opposite Geet Talkies, 491001 New Civic Centre, Sector 6 Bhilai Nagar, Chhattisgarh. 490006 Pan: Aktpm6715H (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None. 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 : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2013-14 Filed By The Assessee Is Directed Against The Order Dated 17.10.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

section 148 of the Act. The consequential assessment, in absence of any compliance during the assessment proceedings by the assessee, the said share transactions aggregating to Rs.1,34,02,971/- was taxed accordingly. Aggrieved, the assessee filed appeal before the Ld. CIT(A). The said first appeal was delayed by 518 days, which was not condoned

MALANI HOLDINGS PRIVATE LIMITED,RAIPUR vs. INCOME TAX OFFICER, WARD 4(1), RAIPUR, RAIPUR

The appeal of the assessee is dismissed, in terms of our aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 316/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

section 251(1)(a) of the Act and failed to adjudicate on legal ground as well as on merits of the case as raised before him. 6. That on the facts and circumstances of the case and in law, the Id. AO as well as CIT(A) erred in making an addition of Rs. 1

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 140/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

1. In the facts and circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals) NFAC has erred in dismissing the appeal on the ground of delay without giving opportunity to appellant before dismissing the appeal by invoking provisions of section 249(3) of the Income- tax Act, 1961. 2. In the facts and circumstances

ANIL NACHRANI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BHOPAL, BHOPAL

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

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 47/Rpr/2022) (Assessment Year: 2012-13)

1 reply, no further notice is required, because reply was already filed by the appellant. The procedure under section 143(2) of the Act is to ensure that an adverse order is issued only after proper opportunity is given to the assessee. In this case, it is conceded that the assessee got opportunity to file reply and detailed reply

SHRIKANT SHARMA, DURG,DURG vs. INCOME TAX OFFICER, WARD-2(1), BHILAI, DURG

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.148/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Shrikant Sharma Village: Birjhapur, Taluka: Dhamdha, Dist: Durg-491 331 (C.G.) Pan: Cayps4948D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Bhilai (C.G.) ……""यथ" / Respondent

Section 5 of the Limitation Act, 1963 regarding the condonation of delay in respect of case of land acquisition has observed and held on the aspect of delay that although the delay cannot be condoned without sufficient cause, the merits of the case could not be discarded solely on the ground of delay. A liberal approach, therefore, should be taken