M/S TRIMURTHY FINVEST LIMITED,BILASPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), BILASPUR

In the result, appeal of the assesse company being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 68, applicable w.e.f from AY 2013-13, not only is the assessee required to explain the source of share application money, but in case the applicant is a company, then the said applicant company is also required to explain the source of money in is handing out of which the amount of share application money was advanced

EAST WEST FINVEST INDIA LIMITED,BILASPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPR

In the result, appeal of the assessee company being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 68, applicable w.e.f from AY 2013-13, not only is the assessee required to explain the source of share application money, but in case the applicant is a company, then the said applicant company is also required to explain the source of money in is handing out of which the amount of share application money was advanced

V Y INSTITUTE OF MEDICAL SCIENCE PRIVATE LIMITED, RAIPUR,RAIPUR vs. ACIT-1(1), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am

section 68 of the Act, which resulted assessed loss at Rs.(-) 43,05,51,858/-. Aggrieved, the assessee filed appeal before the Ld. CIT(A), who dismissed the appeal as under: “5. The final hearing in this case was fixed on 15.04.2024. However, neither the appellant submitted any written submissions nor was any request for adjournment sought by the appellant

SANDEEP KAUR GILL,RAIPUR vs. INCOME TAX OFFICER-3(4), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 267 & 268/Rpr/2022 "नधा"रण वष" / Assessment Year : 2014-15 Sandeep Kaur Gill 26/934, Shukla Colony, Raja Talab, Raipur (C.G.)-492 001 Pan: Adcpg7812K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(4), Raipur (C.G.) ……""यथ" / Respondent

Section 5 of the Limitation Act. 9. We may herein observe that the Hon’ble Apex Court in the case of State of West Bengal Vs. Administrator, Howrah 1972 AIR SC 749, had held that the expression “sufficient cause” should receive a liberal construction so as to advance substantial justice, particularly when there is no motive behind the delay

SANDEEP KAUR GILL,RAIPUR vs. INCOME TAX OFFICER-3(4), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 267 & 268/Rpr/2022 "नधा"रण वष" / Assessment Year : 2014-15 Sandeep Kaur Gill 26/934, Shukla Colony, Raja Talab, Raipur (C.G.)-492 001 Pan: Adcpg7812K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(4), Raipur (C.G.) ……""यथ" / Respondent

Section 5 of the Limitation Act. 9. We may herein observe that the Hon’ble Apex Court in the case of State of West Bengal Vs. Administrator, Howrah 1972 AIR SC 749, had held that the expression “sufficient cause” should receive a liberal construction so as to advance substantial justice, particularly when there is no motive behind the delay

PRADEEP KUMAR KHANDELWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER,-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.46/Rpr/2024 "नधा"रण वष" /Assessment Year : 2011-12 Pradeep Kumar Khandelwal 10/683, Sector Balaji Nagar, Shivnand Nagar, Wrs Colony, Raipur-492 008 (C.G.) Pan: Bjypk5882N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Raipur (C.G.) ……""यथ" / Respondent

condoned the delay of 309 days and remanded the matter back to the Tribunal to adjudicate afresh in accordance with law and on its own merits. 4. Now coming to the merits of the case, the facts as emanated clearly from the order of the Ld. CIT(Appeals)/NFAC are extracted as follows: “5. DECISION: In this case, the assessment

NELSON YONA,RAIPUR vs. INCOME TAX OFFICER, WARD 4(1), RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.181/Rpr/2025 "नधा"रण वष" /Assessment Year : 2011-12 Nelson Yona Near Shiv Mandir, Avanti Vihar, Raipur (C.G.)-492 006 Pan: Adbpy8725E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Ward-4(1), Raipur (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

RAM CHAND PANJWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

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

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 151/Rpr/2023 "नधा"रण वष" / Assessment Year : 2014-15 Ram Chand Panjwani M/S. Gurunanak Rice Mill, Vill : Tulshi, P.O. Tilda, Neora, Raipur (C.G.) Pan : Afbpp5595D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent

68,750/- to the assessee’s returned income. Apart from that the A.O had also made two additions viz. (i) Rs.1,00,000/- on account of freight expenses and hamali expenses as against claimed by the assessee of 6 Ram Chand Panjwani Vs. ITO-1(2), Raipur (C.G.) Rs.15,35,186/- and Rs.32,18,969/- respectively; and (ii) Rs.50

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.

68 on count of unexplained cash credit, being total credits in bank account; when the assessee has only earned commission about 0.15% to 0.20% of total credit entries of Rs. 16,54,79,650 in such bank account; the addition is liable to be deleted." 3. "The appellant craves leave, to add, urge, alter, modify or withdraw any grounds before

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.

68 on count of unexplained cash credit, being total credits in bank account; when the assessee has only earned commission about 0.15% to 0.20% of total credit entries of Rs. 16,54,79,650 in such bank account; the addition is liable to be deleted." 3. "The appellant craves leave, to add, urge, alter, modify or withdraw any grounds before

SHRI DURGA GRAM SERVICE CO OPERATIVE SOCIETY LIMITED MERHANA,BILASPUR vs. INCOME TAX OFFICER - WARD BILASPUR, BILASPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.535/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Shri Durga Gram Service Co-Operative Society Limited Village: Merhana Ghumarwin, Bilaspur, Himachal Pradesh-174 028 Pan: Aagas5856D

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

SEEMA DEVI AGRAWAL,RAIGARH, CHHATTISGARH vs. INCOME TAX OFFICER, BILASPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.250/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Smt. Seema Devi Agrawal C/O. Sunil Kumar Agrawal Sewa Kund Road, Raigarh-496 001 (C.G.) Pan: Affpa4990K .......अपीलाथ" / Appellant बनाम / V/S.

delay has to be well explained. At the same time in these issues a liberal and judicious approach 3 Seema Devi Agrawal Vs. DCIT, Circle-1(1), Bilaspur must be adopted also. Considering the aforesaid facts, I condone the same relying on the judgments of the Hon’ble Supreme Court in the cases of Vidya Shankar Jaiswal Vs. ITO, Ward

PRIYESH SINGHANIA, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.462/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Priyesh Singhania 730/1, Radha Kunj, Opposite Vip Guest House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 Pan: Aoups7838A ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

condone the delay of 57 days involved in the captioned appeal. 5. Both the parties unanimously conceded that the facts and issues involved in the present appeal are exactly identical with the facts in the case of Mitesh Singhania Vs. ITO, Ward-1(2), Raipur, ITA No.410/RPR/2025, dated 22.07.2025. The Tribunal in the aforesaid case had dealt with the similar

RAJENDRA KUMAR SHRIVASTAVA, DURG,DURG vs. ITO, NFAC, DELHI, DELHI

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.744/Rpr/2025 "नधा"रण वष" /Assessment Year : 2020-21 Rajendra Kumar Shrivastava, Mig-42, Padmanabhpur, Durg (C.G.)-491 001 Pan: Alops3921M

68 dated 17/11/1971. My application will be accepted rupees 7,69,000/- be deleted.” 2. At the time of hearing, none appeared for the assessee and no adjournment petition has been filed. The matter was heard after recording the submissions of the Ld. Sr. DR and on a careful perusal of the materials/documents available on record. 3. In this case

PRAKASH KUMAR KSHATRIYA,RAJNANDGAON vs. INCOME TAX OFFICER, WARD-1, RAJNANDGAON, RAJNANDGOAN

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.436/Rpr/2025 "नधा"रण वष" /Assessment Year : 2016-17 Prakash Kumar Kshatriya House No.9, Ward No.44, Kaurin Bhata, Shiv Colony, Rajnandgaon-491 441 (C.G.) Pan: Cdhpk3190B .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1, Rajnandgaon (C.G.) ……""यथ" / Respondent

delay of 42 days is condoned. I take guidance from the judicial pronouncements in the cases of 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 No.17/2025, dated

VEER PROJECTS,RAIPUR vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 654/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

68 of the Act and taxable at special Rate u/s 115BBE 1. Unsecured Loan 2,63,43,671 1. Sundry Creditors 2,56,47,012 Total assessed Income Rs.6,70,06,800 4. Aggrieved with the aforesaid additions, assessee preferred an appeal before the Ld. CIT(A), however, the appeal of assessee has been dismissed in limine, without any adjudication

ANSHUKA TANEJA,AASTHA APARTMENT, SHANKAR NAGAR, RAIPUR vs. INCOME TAX OFFICER, WARD 3(2), CENTRAL REVENUE BUILDING, CIVIL LINES, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No. 391/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Smt. Anshuka Taneja E-7, E-Block, Aastha Apartment, Shankar Nagar, Opposite Wallfort Orchid, Sector-2, Raipur (C.G.)-492 004 Pan: Adupt5936D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(2), Raipur (C.G.) ……""यथ" / Respondent

delay of 743 days is condoned taking guidance from the judicial pronouncements viz. (i) Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur, Civil Appeal Nos……………../2025 [Special Leave Petition (Civil) Nos. 26310- 3 Smt. Anshuka Taneja Vs. ITO, Ward-3(2), Raipur 26311/2024, dated 31.01.2025 (SC); (ii) Jagdish Prasad Singhania Vs. Additional Commissioner of Income Tax (TDS), Raipur

RANCHI FUELS, BALODA BAZAR, BHATAPARA,BALODA BAZAR vs. INCOME TAX OFFICER, BHATAPARA, BHATAPARA

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

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No.532/Rpr/2024 "नधा"रण वष" / Assessment Year : 2017-18 Ranchi Fuels Limtara, Nandghat, Baloda Bazar-492 006 (C.G.) Pan: Aatfr0836L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Bhatapara (C.G.) ……""यथ" / Respondent

Section 68 of the Income Tax Act, 1961 and the Learned CIT (Appeals), National Faceless Appeal Centre, Delhi has erred in confirming the addition to the tune of Rs.26,80,000/- as the addition is contrary to facts, law and legislative intent, hence, it is prayed that the addition of Rs.26,80,000/- confirmed by the Learned CIT (Appeal

DEPUTY COMMISSIONER O F INCOME TAX, RAIPUR vs. BALAJEE LOHA PVT. LTD., RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 356/Rpr/2024 (िनधा"रण वष" Assessment Year: 2014-15)

68 of the Act, it was open to the department to take recourse of section 131 or section 133(6) of the Act, if they were to further proceed, that not having done so, the First Appellate Authority was within its jurisdiction to conclude on facts and law, in favour of the assessee. 6.3 In the case of G. Shubha