SHRI OM PARSHAVNATH DEVELOPERS PVT. LTD.,, DURG,DURG vs. ACIT-1(1), BHILAI, DURG

In the result, appeal filed by the assessee company is allowed for statistical purposes in terms of the aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 23/Rpr/2025 "नधा"रण वष" / Assessment Year : 2015-16 Shri Om Parshvanath Developers Private Limited Nadi Road, Ganjpara, Durg (C.G)-491 001 Pan: Aamcs7665N

Section 5. If sufficient cause is not proved nothing further has to be done; the application for condoning delay has to be dismissed on that ground alone. If sufficient cause is shown then the Court has to enquire whether in its discretion it should condone the delay. This aspect of the matter naturally introduces the consideration of all relevant facts

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’).

delay condonation application by the Ld. CIT(A). The 2nd ground, a legal ground, challenges the validity of reopening of assessment. The 3rd ground is in respect of merit of the additions made in the assessment order. 2 Kamlesh Sharma vs. DCIT, Circle-1(1) 3. The relevant facts giving rise to this appeal are that the assessee filed

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ADDL.COMMISSIONER OF INCOME TAX RANGE -1, BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ADDL.COMMISSIONER OF INCOME TAX RANGE -1, BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

JOINT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), BILASPUR vs. MESERS SOUTH EASTERN COALFIELDS LIMITED, BILASPUR

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

ASSTT.COMMISSIONER OF INCOME TAX CIRCLE-1(1), BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

delay in filing of the cross- objections, which, by no means could be attributed to any mala-fide conduct or a lackadaisical approach on the part of the assessee respondent, therefore, the same did merit to be condoned. 8.7. On merits, it was submitted by the Ld. AR that as per the judgment of the Hon’ble Supreme Court

GRAMIN SEWA SAHAKARI SAMITI, KURUD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, SANKARDAH,DHAMTARI vs. INOCME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, SANKARDAH,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, MADELI,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, KOSMARRA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible

GRAMIN SEWA SAHAKARI SAMITI, BHAKHARA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

253/ hence the net profit from the PDS business comes to Rs 23,767/ and full amount is eligible for deduction u/S80P(2)(GJ(11) for such other business. (v) The Learned AO has only allowed a general deduction of Rs 50,000/ U/S 80P(2)(GJ(11) whereas the entire income of the society is deductible