ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowed amounts in the search proceedings. Further, it is again reiterated that as per the provisions of section 153C, additions can be made only when there is any undisclosed income/unexplained cash or unexplained investment found on the basis of incriminating documents found during course of search " 4.1.5 Respectfully following the binding precedent on this issue, in absence of any incriminating

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowed amounts in the search proceedings. Further, it is again reiterated that as per the provisions of section 153C, additions can be made only when there is any undisclosed income/unexplained cash or unexplained investment found on the basis of incriminating documents found during course of search " 4.1.5 Respectfully following the binding precedent on this issue, in absence of any incriminating

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowed amounts in the search proceedings. Further, it is again reiterated that as per the provisions of section 153C, additions can be made only when there is any undisclosed income/unexplained cash or unexplained investment found on the basis of incriminating documents found during course of search " 4.1.5 Respectfully following the binding precedent on this issue, in absence of any incriminating

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

disallowed amounts in the search proceedings. Further, it is again reiterated that as per the provisions of section 153C, additions can be made only when there is any undisclosed income/unexplained cash or unexplained investment found on the basis of incriminating documents found during course of search " 4.1.5 Respectfully following the binding precedent on this issue, in absence of any incriminating

LOKESHWAR KUMAR SAHU,DHAMTARI vs. INCOME TAX ASSESSING OFFICER, DHAMTARI

The appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.510/Rpr/2025 िनधा"रण वष" /Assessment Year: 2014-15 Lokeshwar Kumar Sahu, Shri Balaji Construction Co. Near Rest House Kathuriya Complex, Ratnabandha Road, Dhamtari, Chhattisgarh. Pan: Ctnps5629H .......अपीलाथ" / Appellant बनाम / V/S.

section 69A despite the assessee having explained 3 Lokeshwar Kumar Sahu, Dhamtari Vs. Income Tax Assessing Officer, Dhamtari the source of funds and routed the loan through account payee transfer. There was no evidence that the funds were unexplained or belonged to the assessee beyond his declared income. 4. The appellant craves leave to add, amend, or withdraw any ground

SARVESH BARDIA,RAJNANDGAON vs. INCOME TAX OFFICER-1, RAJNANDGAON

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.299/Rpr/2024 "नधा"रण वष" / Assessment Year : 2017-18 Sarvesh Bardia Bardia Niwas, Sadar Bazar, Rajnandgaon (C.G.)-491 441 Pan: Aqbpb3485F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Rajnandgaon (C.G.) ……""यथ" / Respondent

disallowing the claim of unsecured loans and treated as unexplained money u/s 69A of the Act is in order and no interference is necessary to modify or otherwise in the impugned order for the said addition of Rs.1,19,30,000/-. Therefore, the ground no.1 of appeal is hereby dismissed.” (B). As regards the addition towards unexplained cash deposits

RASHI STEEL AND POWER LIMITED,BILASPUR vs. ACIT, NEW DELHI

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

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No. 73/Rpr/2021 (Assessment Year: 2012-13) M/S Rashi Steel & Power Ltd. Vs Acit Cf9, Rajeev Plaza, Bilaspur New Delhi Pan No. :Aaecr 6450 Q : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 01/06/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

69A mandates addition only 3 in case the assessee is found to be owner of money, bullion etc. not recorded in the books of account. 12. That the Learned CIT(A) has erred both in law and facts of the case in confirming the addition of Rs.85,00,000/- in the hands of the appellant due to misinterpretation of section

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

Section 69A. The addition made by the A.O and confirmed by the Ld. CIT(A) is arbitrary, illegal and not justified. 2. Without prejudice to above ground, Ld. CIT(A) erred in confirming addition of Rs.9,00,000/- without appreciating the fact that the bank account in which cash deposits/transactions were made does not belong to appellant. 3. The appellant

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)

69A of the Act and tax under section 115BBE was made without any proper basis and in complete disregard of the facts and evidence on record. The assessment was illegal, invalid, contrary to law, and liable to be quashed rather than remanded. The order of CIT(A) is, therefore, unsustainable and requires to be set aside

DINESH KUMAR ACHARYA, BALODA BAZAR,BALODA BAZAR vs. INCOME TAX OFFICER, BHATAPARA, BALODA BAZAR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.109/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Dinesh Kumar Acharya 1, Main Road, Kasdol, Baloda Bazar-493 335 (C.G.) Pan : Afapa4354A .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Bhatapara (C.G.) ……""यथ" / Respondent

disallowances. The appeal before this bench is with regard to the addition u/s. 69A of the Act which was sustained by the Ld. CIT(Appeals)/NFAC. 5. At the time of hearing before this bench, the Ld. Counsel submitted that the source of the cash deposits of Rs.1,50,000/- during demonetization period was out of the accumulated savings

SOURABH AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.845/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Sourabh Agrawal Prop. Sawaria Traders, Shop No.217, Samta Colony, Raipur (C.G.)-492 001 Pan: Apppa0229M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Ward-1(2), Raipur (C.G.) ……""यथ" / Respondent

section 69A of the income tax when the fact remains that the appellant was not liable under Law to maintain any books of accounts. 3. In the facts and circumstances of the case, the Ld. CIT(A) has grossly erred in sustaining addition of Rs.24,04,877/- in respect of entire sales instead of restricting the addition/ disallowance

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)

Section 69A which applies on unaccounted a valuable articles, whereas in present case cash deposit was properly recorded in Cash book maintained by the assessee. 7. Ld. CIT(A) erred in confirming AO’s act of initiation of Penalty under Sec 270A on rental Income of Rs. 1459564/- which was already declared in ITR filed. 8. Ld. CIT(A) erred

RAGHVENDRA SINGH THAKUR, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-4(1), RAIPUR, RAIPUR

The appeal is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.242/Rpr/2025 "नधा"रण वष" /Assessment Year: 2013-14 Raghvendra Singh Thakur, H.No.238, Sarona, Tatibandh, Raipur, 492001, Chhattisgarh Pan: Akbpt7616E .......अपीलाथ" / Appellant बनाम / V/S.

disallowance of Rs.78,220/- confirmed by the Learned CIT (Appeal) may kindly be deleted. 5. The Appellant craves leave to add, amend, alter vary and/or withdraw any or all the above grounds of Appeal.” 2. As per the aforesaid grounds of appeal, Ground No. 4 is consequential and Ground No. 5 is general in nature. 3. That with regard

SHRI VIJAY KUMAR PATEL,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, RAIPUR-1, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 212/Rpr/2024 ("नधा"रण वष" Assessment Year: 2017-18)

69A, 69B, 69C and 69D for any previous year, the assessee shall pay by way of penalty, in addition to tax payable under section 115BBE, a sum computed at a rate of 10% of the tax payable under clause (i) of sub section (1) of section 115BBE. In other words, penalty u/s 271AAC is applicable in this case instead

TEKCHAND PUNJABI, RAIGARH,RAIGARH vs. ITO, WARD-1, RAIGARH, RAIGARH

The appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.569/Rpr/2025 िनधा"रण वष" /Assessment Year: 2016-17 Tekchand Punjabi, C/O Shankar Lal Tekchand, Subhash Chowk, Raigarh, 496001, Chhattisgarh. Pan: Aeqpp2267N .......अपीलाथ" / Appellant बनाम / V/S.

disallowance by the AO regarding cash deposits of Rs.4,21,874/- u/s 69A of the Act as unexplained money in the hands of the assessee, this was affirmed by the Ld. CIT(A)/NFAC. The assessee had explained to the department prior to the deposit of this amount, the assessee had withdrawn through bearer cheque No.5654712 issued in the name

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

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)

69A on account of unexplained money on account of cash deposits in bank account to the tune of Rs. 2,20,24,300/-, also added estimated profit of 8% on Rs. 4,69,64,200/- on credits appearing in the bank account of the assessee maintained with Bank of Baroda having account no. 101205000067, which is calculated at Rs.37

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)

69A on account of unexplained money on account of cash deposits in bank account to the tune of Rs. 2,20,24,300/-, also added estimated profit of 8% on Rs. 4,69,64,200/- on credits appearing in the bank account of the assessee maintained with Bank of Baroda having account no. 101205000067, which is calculated at Rs.37