STEP LOGISTICS PRIVATE LIMITED,RAIPUR vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee in ITA

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.636/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Step Logistics Private Limited A-1, Mahavir Gaushala Complex, K.K Road, Raipur (C.G.)-492 001 Pan: Aancs0382F

144 of the Act. When an estimate is made to the best judgment of an Assessing Officer, he substitutes the income that is to be computed under section 29 of the Act. Once the best judgment assessment is made by fixing a rate of net profit, the assessee's claim for deduction on account of expenses cannot be deemed

HIRA INFRA-TEK LTD., RAIPUR,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.77/Rpr/2023 िनधा"रण वष" /Assessment Year: 2012-13 V. Hira Infra-Tek Limited Acit Hira Arcade Near New Bus Stand, Circle – 1(1) Pandri, Raipur Raipur

disallowance of expenditure under section 144 as made by the Assessee that it is not satisfactory for such cogent reasons

ANIL KUMAR JAIN,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.584 & 585/Rpr/2025 "नधा"रण वष" /Assessment Years : 2018-19 & 2019-20 Anil Kumar Jain 34, Maruti Life Style, Ravi Shankar University, S.O, Raipur-492 010 Pan: Ahypj7657H .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax (Central), Bilaspur (C.G.)

144 of the Act. When an estimate is made to the best judgment of an Assessing Officer, he substitutes the income that is to be computed under section 29 of the Act. Once the best judgment assessment is made by fixing a rate of net profit, the assessee's claim for deduction on account of expenses cannot be deemed

ANIL KUMAR JAIN,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL

In the result, appeal of the assessee in ITA No

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.584 & 585/Rpr/2025 "नधा"रण वष" /Assessment Years : 2018-19 & 2019-20 Anil Kumar Jain 34, Maruti Life Style, Ravi Shankar University, S.O, Raipur-492 010 Pan: Ahypj7657H .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax (Central), Bilaspur (C.G.)

144 of the Act. When an estimate is made to the best judgment of an Assessing Officer, he substitutes the income that is to be computed under section 29 of the Act. Once the best judgment assessment is made by fixing a rate of net profit, the assessee's claim for deduction on account of expenses cannot be deemed

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 4(1), RAIPUR vs. M/S SUPER IRON AND STEEL PVT LTD.,, RAIPUR

In the result, appeal of the revenue is partly allowed and Cross objection of the assessee is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.261/Rpr/2017 ("नधा"रण वष" / Assessment Year :2010-2011) Acit-4(1), Raipur Vs M/S Super Iron & Steel Pvt. Ltd., Pritpal Farm House, Vip Road, Raipur(C.G.) Pan No. : Aaics 2579 R (अपीलाथ" /Appellant) .. (""यथ" / Respondent) & Cross Objection No.13/Rpr/2017 (Arising Out Of Ita No.261/Rpr/2017) ("नधा"रण वष" / Assessment Year :2010-2011) M/S Super Iron & Steel Pvt. Ltd., Vs Acit-4(1), Raipur Pritpal Farm House, Vip Road, Raipur(C.G.) Pan No. : Aaics 2579 R (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

disallowed. The addition is hereby deleted. 28. We have considered the rival submissions. 29. On perusal of the Assessment Order and appellate order, we are live with the fact that the addition made u/s 68 by the Ld AO was on the basis of his presumption that the credit entries shown are representing shortage of cash. Apparently, no enquiry

FIVE STARCONSTRUCTION COMPANY,BHILAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), BHILAI

The appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.45/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 Five Star Construction Company Plot No.96-97, Light Industrial Area, Chawani Chowk, Bhilai (C.G)-490026 Pan : Aaaff4316L .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Bhilai (C.G.) ……""यथ" / Respondent

Section 145(3) of the Act. The A.O after rejecting the books of 9 Five Star Construction Company Vs. DCIT-1(1), Bhilai accounts of the assessee proceeded with to assess its income in the manner provided in Sec. 144 of the Act and made the following additions/disallowances:- S. No. Particulars Amount (In Rs.) 1. Disallowance

NAVRATAN JEWELLERS, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-4(1), RAIPUR, RAIPUR

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: 127/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

disallowance of Rs. 1,52,48,000/- treating the cash deposits and other credits in the bank account as unaccounted income of the assessee covered within the meaning of section 68/69/69A of the Act. 5 Navratan Jewellers Vs. ITO, Ward-4(1), Raipur 4. Aggrieved with the aforesaid addition, assessee preferred an appeal before the Ld. CIT(A), wherein

DAS PROCESSORS,RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER-1 RAJNANDGAON, RAJNANDGAON

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: 780/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Das Processors, 44 Vardhman Nagar Vs Income Tax Officer-1 Jain School Road, Rajnandgaon, Rajnandgaon, Fci Road, Chhattisgarh-491441 Near Raipur Naka Rajnandgaon, Chhattisgarh-491441 Pan: Aaifd6768Q (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 : 09/03/2026 घोषणा की तारीख / Date Of : 12/03/2026 Pronouncement

disallowance of Rs.1,39,84,332/-. 3. The relevant facts giving rise to this appeal are that the assessee, a Civil Contractor, filed its Income Tax Return (‘ITR’) of the relevant year on 31.10.2018 declaring income of Rs.94,72,460/-. The case was picked up for scrutiny and consequential assessment order was passed under section 144

INCOME TAX OFFICER-1, KORBA, KORBA vs. M/S BUDHIA AUTO, MAIN ROAD

Accordingly, ground no. 1 of the appeal of revenue stands dismissed and the disallowance made by Ld

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 158/Rpr/2025 (िनधा"रण वष" Assessment Year: 2012-13)

section 144 of the ITAT, 1961. The only issue raised by the AO in this case is disallowance made u/s 43B of the I. T. Act, 1961. The appellant

SHREE SHYAM SALES CORPORATION,RAIPUR vs. INCOME TAX OFFICER, WARD -1(2), RAIPUR. (C.G.), RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 188/Rpr/2024 (िनधा"रण वष" Assessment Year: 2018-19)

disallowing whole purchases by invoking section 69C - arbitrarily without rejecting books of accounts and without doubting the sales. And also when during the course of assessment proceedings the assessee had submitted the copies of invoices for purchases, GSTR-3B, GSTR-1 and GSTR-2A. And honorable CIT(A), Raipur has been erred for confirming the action of learned assessing officer

SOUTH EASTERN COALFIEDS LIMITED,BILASPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, BILASPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 314/Rpr/2023 "नधा"रण वष" / Assessment Year : 2017-18 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

disallowance inflicted by him in the assessment order on the above issue. (c) Without prejudice to the above. the Ld. AO has erred in law and in facts, in levying penalty u/s.270A without establishing that the explanation furnished by the Appellant was not bona fide and Appellant did not disclose all material facts to substantiate explanation offered

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

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 43/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

disallowance of depreciation on hospital building leased to Apollo Hospitals. 18. That the appellant craves leave to add and /or alter, amend, modify or rescind the grounds hereinabove before or at the hearing of this appeal.” Also, the assessee has raised additional grounds of appeal which reads as under: “1. In the facts and circumstance of the case

DOLPHIN PROMOTERS & BUILDERS, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 440/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

144 read with section 144B of the Act was completed on 28.03.2022, with disallowance of Rs.72,72,000/- u/s 40A(3) of the Act. 4. Aggrieved

RAJESH CHIMNANI L/H LATE SHRI SUDHAM CHAND CHIMNANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.79/Rpr/2025 "नधा"रण वष" / Assessment Year : 2016-17 Rajesh Chimnani, L/H. Late Shri Sudham Chand Chimnani, B-17/7, Near Pani Tanki, New Rajendra Nagar, Raipur (C.G.)-492 001 Pan: Acfpc0343R

disallowance made by the AO is illegal, arbitrary, baseless and not justified. 2. The notice issued u/s.148 and consequent reassessment order passed by AO is illegal inasmuch as the sanction u/s.151 from specified authority is not as per law and without jurisdiction. 3. The reassessment order passed by AO is illegal, bad in law and is liable to be quashed

DINESH KUMAR DIXIT, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(4), RAIPUR, RAIPUR

In the result, the appeal of the assessee is partly allowed in terms of our observations herein above

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.167/Rpr/2023 निर्धारण वर्ष /Assessment Year: 2017-18 Dinesh Kumar Dixit Vs Income Tax Officer 1, Dixit Bhawan, K.K. Road Ward-3(4) Moudhapara, Raipur-492 001 (Cg) Raipur (C.G.) Pan: Actpd 0023H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धारितीती की ओर से /Assessee By : Shri Prafulla Pendse, Ca राजस्व की ओर से /Revenue By : Shri Satya Prakash Sharma, Sr-Dr सुनवाई ाई की तारीख / Date Of Hearing : 22/08/2023 घोषणाणा की तारीख/Date Of Pronouncement : 23/08/2023 आदेश / O R D E R Per Arun Khodpia, Am : This Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 20.03.2023, Arose On The Issues Raised Against The Order Of Assessing Officer Framed U/S 144 Of The Income Tax Act Dated 27.11.2019. The Grounds Of The Appeal Raised By The Assessee Are As Under: “1. That The Order Is Bad In Law As Well As On Facts As The Ld. Cit(A) Has Grossly Erred In Confirming The Action Of Ld. Ao In Making Addition Of Rs.96,43,971/- Under The Income Tax Act, 1961Contrary To The Provisions Of Income Tax Act. 2. The Learned Cit(A) Erred In Sustaining Addition Of Rs.70,31,100/- In Respect Of Alleged Cash Deposits In Bank Account During The Period Of Demonetization, When The Same Is Same At Variance With The Actual Figures Recorded In The Books Of Accounts.

section 144 of the Act. The Ld. AO also issued notices u/s 133(6) of the Act to the ICICI Bank and Vyavasayik Sahakari Bank to provide the Bank Statement of the assessee. In response to these notices, the Vyavasayik Sahakari Bank supplied the bank statement of the assessee. On perusal of the statement of the assessee by Vyavasayik Sahakari

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR vs. CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD., RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 2 & 3/Rpr/2023 Co Nos. 19 & 20/Rpr/2023 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

144 of the Act dated 24.12.2019 r.w order u/ss. 154/144 of the Act dated 09.03.2023, Page 126 of APB; therefore, on the said count itself, in the absence of there being any difference/variance in the deemed total income assessed as per the provisions of Section 115JB as against that determined in its return of income filed u/s.139

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR vs. CHHATTISGARH STATE POWER TRANSMISSION COMPANY LTD., RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 2 & 3/Rpr/2023 Co Nos. 19 & 20/Rpr/2023 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

144 of the Act dated 24.12.2019 r.w order u/ss. 154/144 of the Act dated 09.03.2023, Page 126 of APB; therefore, on the said count itself, in the absence of there being any difference/variance in the deemed total income assessed as per the provisions of Section 115JB as against that determined in its return of income filed u/s.139

INCOME TAX OFFICER WARD 1(1) BILASPUR, BILASPUR vs. RAJSWAY DIRECT TRADING PRIVATE LIMITED, BILASPUR, BILASPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 257/Rpr/2023 "नधा"रण वष" / Assessment Year : 2020-21 The Income Tax Officer, Ward-1(1), Bilaspur .......अपीलाथ" / Appellant बनाम / V/S. Rajsway Direct Trading Private Limited, 1154, Ward No.12, Minimata Nagar, Talapara, Bilaspur (C.G.)-495 001 Pan : Aahcr9787K

144 r.w.s. 144B of the Act dated 30.08.2022. 9. We have thoughtfully considered the issue in hand, i.e., as to whether or not the CIT(Appeals) is right in law and facts of the case in vacating the disallowance of commission expenditure of Rs.3.87 crore (supra) so made by the A.O and are unable to persuade ourselves to concur with