KUSH KEDIA vs. A.C.I.T. 2(1), RAIPUR (CG)

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita Nos. 105 & 106/Rpr/2015 "नधा"रण वष" / Assessment Years : 2004-05 & 2005-06 Kush Kedia Kedia Bhawan, Mandi Road, Balodabazar.Dist. Raipur (C.G.) Pan : Aklpk5127B .......अपीलाथ"/Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-2(1), Raipur. (C.G.) ……""यथ" /Respondent

151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person other than the person referred to in section 153A, then the books of account or documents or assets seized or requisitioned shall be handed

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

151 (1) requires an officer of the rank of the Joint Commissioner to oversee the decision of the AO where the return originally filed was assessed under Section 143 (3) of the Act. Further, where the reopening of an assessment is sought to be made after the expiry of four years from the end of the relevant AY, a further

THE DY. CIT-1(2),, RAIPUR (CG) vs. M/S. SAUMYA MINING LTD.,, RAIPUR (CG)

In the result, appeal filed by the Revenue is dismissed

151 (Gujarat) dated April 3,2013 it was held that: "Section I4A of the Income-tax Act, 1961 - Expenditure incurred in relation to income not includible in total income [Dividends] - Whether where investment was made by assessee in foreign subsidiaries, disallowance

SARTHAK ISPAT PVT. LTD., RAIPUR,RAIPUR vs. INCOME TAX OFFICER-2(1), RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 431/Rpr/2024 ("नधा"रण वष" Assessment Year: 2012-13) Sarthak Ispat Pvt. Ltd., V Income Tax Officer-2(1), Raipur S Udaya Society, Vivekanand Ashram, Raipur, 492001, C.G. Pan: Aalcs5029H (अपीलाथ"/Appellant) . (""थ" / Respondent) . िनधा"रती की ओर से /Assessee By : Shri Subhash Agrawal, Adv. राज" की ओर से /Revenue By : Shri S. L. Anuragi, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 29.01.2025 घोषणा की तारीख/Date Of Pronouncement : 11.02.2025

disallowance is arbitrary, illegal, baseless and not justified. 4. The notice issued by AO u/s 148 is illegal, ab initio void. There was no material before the AO for formation of belief of escapement. The AO reopened the assessment without application of mind and reassessment was initiated only on the basis of Report of DDIT (Inv.), Kolkata. The reassessment proceeding

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

sections, i.e u/s.194C or u/s.194I or u/s.194J of the Act, therefore, no disallowance was called for in 13 M/s. Chhattisgarh Steel & Power Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 the hands of the assessee company u/s 40(a)(ia) of the Act. Ld. AR in support of his aforesaid contention relied on the following judicial pronouncements

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

sections, i.e u/s.194C or u/s.194I or u/s.194J of the Act, therefore, no disallowance was called for in 13 M/s. Chhattisgarh Steel & Power Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 the hands of the assessee company u/s 40(a)(ia) of the Act. Ld. AR in support of his aforesaid contention relied on the following judicial pronouncements

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

151 ITD 566 (Mum.).  Pradeep Khanna vs ACIT order dt. 11.8.2016 of Delhi HC  CIT vs U. P. Electronics Corporation Ltd. (2017) 397 ITR 113 (All) 1.7 In view of the above explanation, it is requested that the disallowance made by AO may kindly be deleted.” 9. With aforesaid submissions, it was the prayer of Learned AR that since assessee

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL-1), RAIPUR, RAIPUR vs. M/S SUNIL SPONGE PVT. LTD., RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.73/Rpr/2022 "नधा"रण वष" / Assessment Year : 2007-08 The Deputy Commissioner Of Income Tax, (Central Circle)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunil Sponge Pvt. Ltd. H. No.11, Jalvihar Colony, Raipur (C.G.)-492 001 (C.G.) Pan : Aahcs7999A ……""यथ" / Respondent

disallowed to determine book profits under Section 115JB of the Act. The above query of the Assessing Officer was responded to by the Petitioner in great detail by its letters dated 10 October 2017 and 21 December 2017. It justified its claim for deductions by placing reliance upon the decisions of the Courts. in support of its contention that they

M/S JMD CRUSHER, JAGDALPUR,BASTAR vs. INCOME TAX OFFICER, WARD- JAGDALPUR, BASTAR

Appeals of the assessee are partly allowed for statistical purposes, in terms of our aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 102, 103 & 104/Rpr/2025 (िनधा"रण वष" Assessment Year:2017-18)

section 147 to 151 of the Income Tax Act, 1961. The contention of the appellant has been considered. I have gone through the facts and found that the proceedings against appellant were opened u/s 147 of the Income Tax Act, 1961 after obtaining approval from the competent authority. During the course of proceedings, the Assessing Officer issued the notice

M/S JMD CRUSHER, JAGDALPUR,BASTAR vs. INCOME TAX OFFICER-JAGDALPUR, BASTAR

Appeals of the assessee are partly allowed for statistical purposes, in terms of our aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 102, 103 & 104/Rpr/2025 (िनधा"रण वष" Assessment Year:2017-18)

section 147 to 151 of the Income Tax Act, 1961. The contention of the appellant has been considered. I have gone through the facts and found that the proceedings against appellant were opened u/s 147 of the Income Tax Act, 1961 after obtaining approval from the competent authority. During the course of proceedings, the Assessing Officer issued the notice

M/S JMD CRUSHER, JAGDALPUR,BASTAR vs. INCOME TAX OFFICER, WARD-JAGDALPUR, BASTAR

Appeals of the assessee are partly allowed for statistical purposes, in terms of our aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 102, 103 & 104/Rpr/2025 (िनधा"रण वष" Assessment Year:2017-18)

section 147 to 151 of the Income Tax Act, 1961. The contention of the appellant has been considered. I have gone through the facts and found that the proceedings against appellant were opened u/s 147 of the Income Tax Act, 1961 after obtaining approval from the competent authority. During the course of proceedings, the Assessing Officer issued the notice

MESERS METEX ENGINEERS,BHILAI vs. INCOME TAX OFFICER, WARD-1(2), BHILAI

In the result Ground No 8 of the revenue is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.238/Rpr/2019 (Assessment Year: 2015-2016) M/S Metex Engineers, Vs Ito, Ward-1(2), Bhilai Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G & आयकर अपील सं./Ita No.247/Rpr/2019 (Assessment Year: 2015-2016) Ito, Ward-1(2), Bhilai Vs M/S Metex Engineers, Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri R.B.Doshi, Ca राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 24/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 14/06/2023 आदेश / O R D E R Per Arun Khodpia, Am :

section 14A r.w.r.8D. As the reply filed by the assessee did not find favor with the Assessing Officer, therefore, he worked out the disallowance u/s.14A r.w.r.8D at Rs.13,29,277/-. 7. Before us, it was submitted by the Ld. Authorized Representative (for short ‘AR’) that as the assessee has not earned any exempt dividend income during the year under consideration

INCOME TAX OFFICER, WARD-1(2), BHILAI vs. MESERS METEX ENGINEERS, BHILAI

In the result Ground No 8 of the revenue is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.238/Rpr/2019 (Assessment Year: 2015-2016) M/S Metex Engineers, Vs Ito, Ward-1(2), Bhilai Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G & आयकर अपील सं./Ita No.247/Rpr/2019 (Assessment Year: 2015-2016) Ito, Ward-1(2), Bhilai Vs M/S Metex Engineers, Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri R.B.Doshi, Ca राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 24/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 14/06/2023 आदेश / O R D E R Per Arun Khodpia, Am :

section 14A r.w.r.8D. As the reply filed by the assessee did not find favor with the Assessing Officer, therefore, he worked out the disallowance u/s.14A r.w.r.8D at Rs.13,29,277/-. 7. Before us, it was submitted by the Ld. Authorized Representative (for short ‘AR’) that as the assessee has not earned any exempt dividend income during the year under consideration