INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

disallowed. 5.5.5. The appellant has also asserted that "In spite of submitting all evidences, the Ld. AO has observed that the assessee provided the combined profit and loss statement of share trading in the books of Exclusive Securities ltd. But the source of investment towards purchase of shares has not been provided. In response to same, the appellant begs

CHHATTISGARH STATE BEVERAGES LTD.,RAIPUR vs. PR. COMMISSIONER OF INCOME TAX-1, RAIPUR

In the result, appeals of the assessee in ITA Nos

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita Nos.38, 39 & 40/Rpr/2021 "नधा"रण वष" / Assessment Years : 2015-16, 2016-17 & 2017-18 Chhattisgarh State Beverages Corporation Limited Aabkari Bhavan, Chokra Nala, Labhandi, Raipur-492 001 Pan : Aaccc3163B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1 (C.G.) ……""यथ" / Respondent

disallowance of VAT expenses amounting to Rs. 53,65,46,087/-. Same is bad in law, against law of natural justice

CHHATTISGARH STATE BEVERAGES CORPORATION LTD.,RAIPUR vs. PR. CIT-1, RAIPUR

In the result, appeals of the assessee in ITA Nos

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita Nos.38, 39 & 40/Rpr/2021 "नधा"रण वष" / Assessment Years : 2015-16, 2016-17 & 2017-18 Chhattisgarh State Beverages Corporation Limited Aabkari Bhavan, Chokra Nala, Labhandi, Raipur-492 001 Pan : Aaccc3163B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1 (C.G.) ……""यथ" / Respondent

disallowance of VAT expenses amounting to Rs. 53,65,46,087/-. Same is bad in law, against law of natural justice

CHHATTISGARH STATE BEVERAGES LTD.,RAIPUR vs. PR. COMMISSIONER OF INCOME TAX-1, RAIPUR

In the result, appeals of the assessee in ITA Nos

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita Nos.38, 39 & 40/Rpr/2021 "नधा"रण वष" / Assessment Years : 2015-16, 2016-17 & 2017-18 Chhattisgarh State Beverages Corporation Limited Aabkari Bhavan, Chokra Nala, Labhandi, Raipur-492 001 Pan : Aaccc3163B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1 (C.G.) ……""यथ" / Respondent

disallowance of VAT expenses amounting to Rs. 53,65,46,087/-. Same is bad in law, against law of natural justice

VIJAY KUMAR CHHATTANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita No.120/Rpr/2024 "नधा"रण वष" /Assessment Year: 2016-17 Vijay Kumar Chhattani, S.S.D. Agro Tech Building, Village Tulsi, Neora, Tilda, Raipur, Chhattisgarh Pan: Afapc4410R .......अपीलाथ" / Appellant बनाम / V/S.

disallowed 25% of such purchase expenses on account of bogus transactions 5.1 In the case of Ratnagiri Stainless (P.) Ltd [2017, 164 ITD 136], ITAT Mumbai held that, the assessee failed to prove the onus cast upon it to prove that purchases made by the assessee were genuine purchases, which were held by the authorities below to be bogus purchases

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

disallowed u/s 69C of the Income tax Act, 1961” The assessee stated vide order sheet dated 07/12/2016 that:- "all the purchase and sale made by the assesses during the F.Y. 2013- 14 is genuine, stock of material has been duly received & dispatched. Further, such transactions are recorded properly in the books of accounts and stock register

ASHOK KUMAR WADHWANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.117 &118/Rpr/2024 "नधा"रण वष" /Assessment Year: 2014-15 & 2016-17 Ashok Kumar Wadhwani, Ujwal Udyog, Sinodha, Neora, Tilda, Raipur, Chhattisgarh. Pan: Aahpw1400B .......अपीलाथ" / Appellant बनाम / V/S.

disallowed u/s 69C of the Income tax Act, 1961” The assessee stated vide order sheet dated 07/12/2016 that:- "all the purchase and sale made by the assesses during the F.Y. 2013- 14 is genuine, stock of material has been duly received & dispatched. Further, such transactions are recorded properly in the books of accounts and stock register

THE ASSISTANT COMMISSIONER OF INCOME-TAX-2(1)BHILAI, BHILAI(CG) vs. M/S SMS SHIVNATH INFRASSTRUCTURE PVT LTD., DURG, DURG(CG)

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowable interest, being a ground for which no opportunity of being heard being accorded to the Appellant, is violative of the principles of natural justice

M/S SMS SHIVNATH INFRASTRUCTURE PVT LTD,DURG(CG) vs. THE PR. COMMISSIONER OF INCOME TAX-2, RAIPUR (CG)

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowable interest, being a ground for which no opportunity of being heard being accorded to the Appellant, is violative of the principles of natural justice

RAVI RAIKA,BHILAI vs. ACIT-1(1), BHILAI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.422 & 423/Rpr/2025 "नधा"रण वष" / Assessment Years : 2017-18 & 2015-16 Ravi Raika 22/4, Nehru Nagar West, Bhilai (C.G.)-490 020 Pan: Acjpa2125R ........अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Bhilai (C.G.)

natural justice by the Ld. CIT(Appeals)/NFAC, we refer to Para 3 Ravi Raika Vs. ACIT-1(1), Bhilai (C.G.) ITA Nos. 422 & 423/RPR/2025 6.1.1 of the Ld. CIT(Appeals)/NFAC order in ITA No.422/RPR/2025 for A.Y.2017-18 and the same is extracted as follows: “6.1.1. Now before me in the appellate proceedings, the appellant has filed written submission

RAVI RAIKA,BHILAI vs. ACIT-1(1), BHILAI

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.422 & 423/Rpr/2025 "नधा"रण वष" / Assessment Years : 2017-18 & 2015-16 Ravi Raika 22/4, Nehru Nagar West, Bhilai (C.G.)-490 020 Pan: Acjpa2125R ........अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Bhilai (C.G.)

natural justice by the Ld. CIT(Appeals)/NFAC, we refer to Para 3 Ravi Raika Vs. ACIT-1(1), Bhilai (C.G.) ITA Nos. 422 & 423/RPR/2025 6.1.1 of the Ld. CIT(Appeals)/NFAC order in ITA No.422/RPR/2025 for A.Y.2017-18 and the same is extracted as follows: “6.1.1. Now before me in the appellate proceedings, the appellant has filed written submission

SMT. YOGITA DEVI SAHU, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.182 & 183/Rpr/2025 "नधा"रण वष"/Assessment Year : 2013-14 Smt. Yogita Devi Sahu W/O. Late Sri Tikaram Sahu, C/O. Sri Sujit Kumar Sahu Vindhya Vasini Nagar, Nayak Bandha, Abhanpur Dist. Raipur-493 661 (C.G.) Pan: Cdtps1353N ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Raipur (C.G.) ……""यथ" / Respondent

justice coupled with liberal and judicious approach while deciding the issue of limitation and whenever it is found that the case has merits which needs to be addressed substantially, in such case, the delay should be condoned. Accordingly, the said delay of 559 and 407 days, respectively involved in the captioned appeals are condoned. 4. We shall first take

SMT. YOGITA DEVI SAHU, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.182 & 183/Rpr/2025 "नधा"रण वष"/Assessment Year : 2013-14 Smt. Yogita Devi Sahu W/O. Late Sri Tikaram Sahu, C/O. Sri Sujit Kumar Sahu Vindhya Vasini Nagar, Nayak Bandha, Abhanpur Dist. Raipur-493 661 (C.G.) Pan: Cdtps1353N ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Raipur (C.G.) ……""यथ" / Respondent

justice coupled with liberal and judicious approach while deciding the issue of limitation and whenever it is found that the case has merits which needs to be addressed substantially, in such case, the delay should be condoned. Accordingly, the said delay of 559 and 407 days, respectively involved in the captioned appeals are condoned. 4. We shall first take

NANESH PROJECTS,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

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

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

natural justice and uncalled for; disallowance made and, sustained may kindly be deleted. 4. Ground 3: Disallowance for delay in payment

INCOME TAX OFFICER, RAIPUR vs. SANJAY KUMAR PUNJABI, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.565/Rpr/2025 िनधा"रण वष" /Assessment Year: 2019-20 Income Tax Officer, Central Revenue Building, Civil Lines, Raipur, Chhattisgarh, 492001 .......अपीलाथ" / Appellant बनाम / V/S.

disallowance of claim u/s 80GGC and 3 Income Tax Officer Vs. Sanjay Kumar Punjabi Rs.73,513/- as unexplained money u/s 69A r.w.s. 115BBE of the Act. Penalty proceedings were separately initiated against the assessee. In this regard, there was no compliance by the assessee before the Ld. CIT(Appeals)/NFAC, which is evident from paragraphs

SUDHA GUPTA,BILASPUR vs. THE INCOME TAX OFFICER, BILASPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 435/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

disallowance amounting to Rs. 66,69,430/-. 5. Aggrieved with the aforesaid order, assessee preferred an appeal before the Ld. CIT(A) which has been dismissed on ex-parte basis. 6. Dissatisfied with the order of Ld. CIT(A), the matter is carried before us by the assessee, which is under consideration. 7. On perusal of the order

DINESH KUMAR MISHRA, KAWARDHA,KABIRDHAM vs. ITO-1(3), BHILAI, (ERSTWHILE ITO WARD KAWARDHA), BHILAI

Appeal of the assessee is allowed for statistical purposes, in terms of over aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 345/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

disallowance of Rs. 1,50,000/- from Loading, Handling of Bauxite Expenses. 4 ITA 345/RPR/2025 Dinesh Kumar Mishra vs. ITO-1(3), Bhilai, (Erstwhile ITO Ward Kawardha), Bhilai The aforesaid additions were made as the assessee was unable to substantiate these expenses, for the reason that there are handwritten / self- made Vouchers, which are not fully verifiable and also

VEER PROJECT,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 332/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18)

Natural justice by not allowing proper opportunity of being heard. 2. That on the facts and in the circumstances of the cases and in law, the order u/s 143(3) of the Act passed by the assessing officer dated 20/12/2019 is without valid jurisdiction in accordance with section 127(3) of the Act and liable to be quashed. 3. That