MADHYANI BUILDERS, BHILAI,DURG vs. INCOME TAX OFFICER, CIRCLE-1(1), BHILAI, DURG

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: 189/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23)

250 of the Income Tax Act, 1961 (in short “the Act”), which in turn arises from the intimation u/s 143(1) of the Act, dated 30.12.2023, issued by Centralized Processing Center, Bengaluru (in short “Ld. AO”). 2 Madhyani Builders Vs Income Tax Officer, Circle-1(1), Bhilai 2. The grounds of appeal raised by the assessee are as under

M/S R D CONSTRUCTION, BHILAI,BHILAI vs. ITO, WARD-1(5), BHILAI, BHILAI

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.640/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 M/S. R D Construction Shikshit Nagar, Near Bus Stand, Bhilai Marshalling Yard, Charoda, Bhilai-490 025 (C.G.) Pan: Aajfr3698E

disallowance to 20% again on ad-hoc basis without compliance to Section 250(4) & (6) of the Act and resultantly

M/S M SUBBA RAJU,VIJAYAWADA vs. INCOME TAX OFFICER-1, RAJNANDGAON, RAJNANDGAON

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.19/Rpr/2025 "नधा"रण वष" /Assessment Year: 2017-18 M/S. M Subba Raju D. No.32-12-16, Flat No.401, Sri Sri Kakatiya Towers, Boyapati Madhavrao Street, Mogalrajpuram, Vijaywada Pan: Aaefm3293R .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Rajnandgaon (C.G) ……""यथ" / Respondent

disallowed an amount of Rs.9 lacs as unexplained money u/s.69A of the Act. It was explained by the assessee that as regards the amount of Rs.9 lacs, the same was deposited by the partner of the assessee. However, due to similarity in the name of 3 M/s. M Subba Raju Vs. ITO-1, Rajnandgaon the assessee as well

KIRAN AGRAWAL, RAIPUR,RAIPUR vs. ITO, DHAMTARI, DHAMTARI

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: 655/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23)

disallowance/ addition is highly unjustified, unwarranted, uncorroborated, untenable, not proper on facts of the case, based on conjectures & surmises and not in accordance with the provisions of law and it is requested that the same may please be deleted. 4. On the facts and circumstances of the case as well as in law, the Ld. CIT(A) has grievously erred

SHARAD GOEL, RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 310/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

250(4) and (6) of the Act which are not adhered to by him, we find it appropriate to restore this matter back to the file of Ld. Addl/JCIT(A) for fresh adjudication. 9. Adverting to the second issue regarding ad-hoc disallowance of 5% from Discount, Repair & Maintenance, Workshop Expenses amount to Rs.2,69,315/- and herein also

SPIN PACKAGING LTD., BILASPUR,BILASPUR vs. DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX-2(1), BILASPUR, BILASPUR

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: 165/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18)

250 of the Income Tax Act, 1961 (in short “the Act”), dated 23.01.2025, for the Assessment Year 2017-18, which in turn arises from the assessment order u/s 143(3) of the Act, dated 19.12.2019 passed by Assistant Commissioner of Income Tax, DC/ACIT-2(1), Bilaspur, (in short “Ld. AR”). 2 Spin Packaging Ltd. Vs. DCIT/ACIT-2(1), Bilaspur 2. The grounds

SHREE KRISHNA UDYOG, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-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 आयकर अपील सं. / Ita No: 841/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Shree Krishna Udyog, 17A, Vs Income Tax Officer, Ward 1(1), Bhanpuri Industrial Area, Aaykar Bhawan, Civil Lines, Raipur, Chhattisgarh, 492010 Raipur Chhattisgarh, 492001 Pan: Aapfs5659E (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri G. S. Agrawal, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 16/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

section 250 of the Income Tax Act, 1961 (‘Act’). 2. The appellant assessee has raised following grounds of appeal: - “1. That under the facts and the law, the Order of below authorities are bad in law and on facts. Disallowance of Rs. 53,32,200/- kindly be deleted. 2. That under the facts and the law, the Ld. Commissioner

GURMEET SINGH HORA,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 358, 359 & 360/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20, 2020-21 & 2021-22)

section 250 of the Income Tax Act, 1961 (in short “the Act”), all dated 17.03.2025, for the Assessment Year 2019-20, 2020-21 and 2021-22, which in turn arises from the intimation issued u/s 143(1) of the Act, dated 14.07.2020, 24.12.2021 and 21.11.2022, respectively. Gurmeet Singh Hora vs. Deputy Commissioner of Income Tax-1(1) 2. Since

GURMEET SINGH HORA,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 358, 359 & 360/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20, 2020-21 & 2021-22)

section 250 of the Income Tax Act, 1961 (in short “the Act”), all dated 17.03.2025, for the Assessment Year 2019-20, 2020-21 and 2021-22, which in turn arises from the intimation issued u/s 143(1) of the Act, dated 14.07.2020, 24.12.2021 and 21.11.2022, respectively. Gurmeet Singh Hora vs. Deputy Commissioner of Income Tax-1(1) 2. Since

GURMEET SINGH HORA,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 358, 359 & 360/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20, 2020-21 & 2021-22)

section 250 of the Income Tax Act, 1961 (in short “the Act”), all dated 17.03.2025, for the Assessment Year 2019-20, 2020-21 and 2021-22, which in turn arises from the intimation issued u/s 143(1) of the Act, dated 14.07.2020, 24.12.2021 and 21.11.2022, respectively. Gurmeet Singh Hora vs. Deputy Commissioner of Income Tax-1(1) 2. Since

MANOJ KUMAR JAIN, 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 Chaudhuryआयकर अपील सं./Ita No.77/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Manoj Kumar Jain M/S. Vidyashree Trading, Ghul Ghul, Tilda, Neora, Raipur (C.G.)-493 114 Pan: Achpj6480G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G) ……""यथ" / Respondent

250(6) of the Act, allowing the deduction of interest on unsecured loans as a valid claim and dismissing the demand raised. However, upon examining the appellant's submissions and the relevant provisions of the Income Tax Act, it is evident that the claim for interest on unsecured loans lacks merit. Section 36(1)(iii) of the Act allows

GURMUKH DAS GANGWANI, BHATAPARA,BHATAPARA vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 246/Rpr/2022 "नधा"रण वष" / Assessment Year : 2016-17 Gurmukh Das Gangwani House No.199, Gurunanak Ward, Bhatapara (C.G.)-493 118 Pan : Ainpg1689A .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Raipur (C.G.). ……""यथ" / Respondent

disallowance of 25 percent of the amount of purchases made from certain parties u/s 145(3) even there was no suppression of profits. 3. That the assessee craves leave to add, urge, alter, modify and with draw any ground/grounds before or at the time of hearing of the appeal.” 2. Succinctly stated, the assessee who is engaged in the business

DEPUTY COMMISSIONER OF INCOME TAX -1(1), RAIPUR vs. BHARAT AGRO INDUSTRIES, RAIPUR

In the result, the appeal of the Revenue is partly allowed as above

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

250 of the Income Tax Act, 1961 (‘Act’). 2. The following grounds of appeal have been taken by the revenue: - “1. Whether on the facts and in the circumstance of the case and in law, the Ld CIT(A) was justified in deleting the addition made by the AO to the tune of Rs 2,00,23,554 on account

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

250 (SC), 257 Taxman 2 (SC) SLP dismissed against High Court ruling that section 14A cannot be invoked where no exempt income was earned by assessee in relevant assessment year.  Cheminvest Ltd. vs CIT (2015) 378 ITR 33 (Del.).  Nutan Ispat & Power P. Ltd vs DCIT in ITA no. 80/RPR/2016 dt 17.08.2018 :: 6 :: In this case, jurisdictional Raipur Bench

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

KHANDELWAL INDUSTRIES, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD- DHAMTARI, DHAMTARI

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.551/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Khandelwal Industries Industrial Area, Dhamtari Chhattisgarh-493 773 Pan: Aaqfk4740D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Dhamtari (C.G.) ……""यथ" / Respondent

Section 250 (4) & (6) of the Act, the Ld.CIT(Appeals)/NFAC should have conducted necessary inquiry regarding the genuineness of the submissions made by the assessee that 6 Khandelwal Industries Vs. ITO, Ward-Dhamtari cash in hand was formed from withdrawal of Rs.7,00,000/- from Khandelwal Industries. 5. That since the principles of natural justice was not followed

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c) of the Act, dated 19.02.2013 before the CIT(A), who partly sustained the order of the A.O, observing as under:- “2.3 After considering the explanation furnished by the appellant company, the AO imposed penalty under the aforesaid section for furnishing inaccurate particulars of 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

6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c) of the Act, dated 19.02.2013 before the CIT(A), who partly sustained the order of the A.O, observing as under:- “2.3 After considering the explanation furnished by the appellant company, the AO imposed penalty under the aforesaid section for furnishing inaccurate particulars of income

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c) of the Act, dated 19.02.2013 before the CIT(A), who partly sustained the order of the A.O, observing as under:- “2.3 After considering the explanation furnished by the appellant company, the AO imposed penalty under the aforesaid section for furnishing inaccurate particulars of income