M/S. G.P. INFRAVENTURES ,RAIPUR vs. INCOME TAX OFFICER-1(4), RAIPUR

The appeal of the department stands disposed off

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

section 40A (3) is clearly attracted? 2. Whether on the facts and circumstances of the case, the Id. CIT(A) was justified in deleting the addition of Rs. 1,42,85,000/- by way of disallowance u/s 40A(3) of the IT Act on account of amount paid towards purchase of land which is stock-in trade of the assessee

RAVI SHERWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX -4(1), RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 64/Rpr/2020 "नधा"रण वष" / Assessment Year : 2013-14 Ravi Sherwani H-26, Rajeev Nagar, Raipur (C.G.)-492 001 Pan: Azbps6703J .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-4(1), Raipur (C.G.)

disallowing cost of improvement of Rs.1,11,02,013.00 without going through actual facts and circumstances. 4. The appellant reserves the right to amend, modify or add any of the grounds of appeal.” Also, the assessee has raised an additional ground of appeal before us, which reads as under: “On the facts and circumstances of the case

M/S MATA ROAD CARRIERS,RAIPUR (CG) vs. THE DEPUTY COMMISSIONER OF INCOME TAX, RAIPUR (CG)

In the result, appeal of the assessee is allowed

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

disallowed and added under section 40a(ia) of the Act.( Para-8 page-4) 9. CIT observation: - The CIT appeal confirmed the above addition Para 2.3 Page 4 10. The assessee has challenge the notice under section 143(2) and assessment order passed under section 143(3) by the DCIT Circle-1, Raipur. Apart from the above submissions

MICKEY SHRIVASTVA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX -3(1), RAIPUR

In the result, appeal of the assessee is allowed

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

disallowances will be made. 5. That the appellant craves leave to add, alter or modify the ground of appeal any time before or at the time of hearing of the appeal. 8. Further the assessee has filed additional ground vide an application dated 26.12.2022, which reads as under :- The assessee wants to raise 'additional ground' of appeal, which

ASSISTANT COMMISSIONER OF INCOME TAX (CENTRAL)-I, RAIPUR vs. MESERS CHHATTISGARH STEEL & POWER LIMITED, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

2 raised by the revenue is dismissed in terms of our aforesaid observations. (C). Re. Disallowance u/s 40(a)(ia) of transmission charges: Rs. 1,18,63,401. 18. It transpires on a perusal of the assessment order that the assessee company had debited an amount of Rs.1,18,63,401/- in its Profit & loss account towards transmission charges which

ASSISTANT COMMISSIONER OF INCOME TAX, (CENTRAL)-I, RAIPUR vs. MESERS CHHATTISGARH STEEL & POWER LIMITED, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

2 raised by the revenue is dismissed in terms of our aforesaid observations. (C). Re. Disallowance u/s 40(a)(ia) of transmission charges: Rs. 1,18,63,401. 18. It transpires on a perusal of the assessment order that the assessee company had debited an amount of Rs.1,18,63,401/- in its Profit & loss account towards transmission charges which

M/S ADARSH RICE MILL,RAIPUR vs. INCOME TAX OFFICER, WARD 1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No.84/Rpr/2022 "नधा"रण वष" / Assessment Year : 2011-12 M/S. Adarsh Rice Mill 123, Jhanki, Abhanpur, Dist.-Raipur (C.G.)-492 001 Pan : Aamfa1207F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Raipur (C.G.) ……""यथ" / Respondent

disallowing 25% of the impugned bogus purchases of Rs.7,58,800/-, the A.O determined the income of the assessee firm at Rs.2,26,130/-. 3. Aggrieved, the assessee carried the matter in appeal before the CIT(Appeal) but without any success. 4. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before

M/S M/S GOYAL CONSTRUCTION COMPANY, RAIPUR,RAIPUR (CG) vs. THE INCOME TAX OFFICER, 3(1),RAIPUR, RAIPUR (CG)

In the result, appeal of the assessee is partly allowed for statistical purposes in terms of my aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 17/Rpr/2017 "नधा"रण वष" / Assessment Year : 2012-13 M/S. Goyal Construction Company Shop No.213-214, Ii Floor, Crystal Arcade, Lodhipara Chowk, Raipur (C.G.) Pan : Aaffg9964N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-3(1), Raipur (C.G.). ……""यथ" / Respondent

disallowances. 5. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before me. 5 M/s. Goyal Construction Company Vs. ITO-3(1), Raipur 6. As the assessee has assailed the validity of jurisdiction that was assumed by the A.O, i.e., ITO, Ward-3(1), Raipur for framing the assessment vide his order

SAIRAM WHEELS PRIVATE LIMITED,BHILAI vs. INCOME TAX OFFICER, WARD-1(1) , BHILAI

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 127/Rpr/2019 "नधा"रण वष" / Assessment Year : 2015-16 Sairam Wheels Pvt. Ltd. Krishna Nagar, Near Supela Police Station G.E. Road, Bhilai, Dist. Durg-490023 Pan : Aaocs8188G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Durg (C.G.). ……""यथ" / Respondent

section 124 of the Act, notification no. 1/2014-15 dt. 15.11.2014 issued by the PCIT-II, Raipur to allocate jurisdiction to various AO's under his jurisdiction and judicial pronouncement referred by the appellant. 2) That learned CIT(A) erred in confirming disallowance

AARTI SPONGE AND POWER LTD.,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, -1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.70/Rpr/2023 िनधा"रण वष" /Assessment Year: 2013-14 V. Aarti Sponge & Power Ltd. Acit -1 (1) Aarti House, Ashoka Ratna Shankar Raipur Nagar, Raipur, Chhattisgarh – 492 001

disallowance under Section 14A will still be attracted. which reads as under: :: 14 :: “In section 14A of the Income-tax Act, – (a) in sub-section (1), for the words “For the purposes of”, the words “Notwithstanding anything to the contrary contained in this Act, for the purposes of” shall be substituted; (b) after the proviso, the following Explanation shall

THE DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1)BILASPUR, BILASPUR(CG) vs. THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR,BILASPUR(CG) vs. THE DY. COMMISSIONER OF INCOME TAX,CIRCLE , 1(1)BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

SOUTH EASTERN COALFIELDS LTD,BILASPUR(CG) vs. DY.. C.I.T.-1(1), BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG) vs. SOUTH EASTERN COAL FIELDS LTD.,, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

2(45) of the Act and it means the total amount of income computed in the manner laid down in the Act. Thus, for arriving at the total income, the income derived from all sources is to be considered as provided by section 5, when it is received or deemed to be received by a person. All income