M/S DURG EDUCATION AND CHARITABLE SOCIETY,DURG(CG) vs. THE COMMISIONER OF INCOME TAX, EXEMPTION, BHOPAL

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.35/Rpr/2016 "नधा"रण वष" / Assessment Year : 2014-15 Durg Education & Charitable Society, Hig 110, Padmanabhpur, Durg (C.G.)-491 001 Pan : Aaaad3802C .......अपीलाथ" / Appellant बनाम / V/S. The Commissioner Of Income Tax (Exemption), Bhopal ……""यथ" / Respondent Assessee By : None Revenue By : Shri P.K Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 25.07.2022 घोषणा क" तार"ख / Date Of Pronouncement : 09.09.2022

section 10(23C)(vi), the Chief Commissioner of Income Tax can exercise any such power”. On the basis of the aforesaid position of law, we are of the considered view that as the Commissioner of Income-Tax (Exemption), Bhopal was not vested with any power to condone the delay involved in filing of the application by the assessee society under

MANAV RACHNA EDUCATION SOCIETY,RAIPUR vs. COMMISSIONER OF INCOME TAX ( EXEMPTION), BHOPAL

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita No. 01/Rpr/2021 "नधा"रण वष" / Assessment Year : 2018-19 Manav Rachana Education Society, A-1, Pushpak Apartments, Opp. Government School, Chhotapara, Raipur (C.G.)-492 001 Pan: Aaaac6228R . ......अपीलाथ" / Appellant बनाम / V/S.

section 10(23C)(vi), the Chief Commissioner of Income Tax can exercise any such power”. On the basis of the aforesaid position of law, we are of the considered view that as the Commissioner of Income-Tax (Exemption), Bhopal was not vested with any power to condone the delay involved in filing of the application by the assessee society under

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

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

34,253/ 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

34,253/ 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, DONAR,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, BHENDRI ,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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

34,253/ 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, KODEBOD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, KODEBOD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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

34,253/ 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, BHENDRI,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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, KURUD,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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

34,253/ 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

34,253/ 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, DOMA,DHAMTARI vs. INCOME TAX OFFICER, DHAMTARI, DHAMTARI

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

Bench: Shri Ravish Sood

34,253/ 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