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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

THE DY. CIT- CIR.-1(1),, BILASPUR(CG) vs. SOUTH EASTERN COALFILDS LTD.,, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

3. Disallowance out of guest house For “furnishing inaccurate expenses particulars of income” 4. Disallowance of expenditure on assets For “concealment of not belonging to the assessee company income” 5. Disallowance of payment made to ESM For “furnishing inaccurate transporters particulars of income” 6. Aggrieved, the assessee assailed the order passed by the A.O under Sec.271(1)(c

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

Section 120 of the Act, therefore, we are not inclined to accept the aforesaid claim of the department. We, thus, in terms of our aforesaid observations are unable to concur with the Ld. DR that the Income-Tax Officer, Ward-1(2), Jabalpur was validly vested with the jurisdiction over the case of the assessee on the basis of allocation

HITESH GOLCHHA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are partly allowed, in terms of our observations herein above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.101, 102, 103 & 104/Rpr/2022 (िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18) V. Hitesh Golchha Acit, Prop. Of Mouli Investment, Central Circle-1 Jeevan Ganga, Near Dani Bada, Raipur Budha Para, Raipur – 492 001 Chhattisgarh [Pan: Agjpg 7698 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri B. Subramanyam, C.A. ""यथ" क" ओर से /Respondent By : Shri S. K. Meena, Cit-D.R. सुनवाई क" तार"ख/Date Of Hearing : 13.09.2023 घोषणा क" तार"ख /Date Of Pronouncement : 02.11.2023

13 of paper book) 1.4. As there was no personal hearing was provided by the Ld. PCIT within reasonable time, further written submission dated 25.02.2022 and 07.03.2022 with necessary evidences were as filed online. (Please refer page no. 9 to 12 of paper book) 1.5. The Ld. PCIT has not accepted the prayer of Appellant to provide for an opportunity

HITESH GOLCHHA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are partly allowed, in terms of our observations herein above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.101, 102, 103 & 104/Rpr/2022 (िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18) V. Hitesh Golchha Acit, Prop. Of Mouli Investment, Central Circle-1 Jeevan Ganga, Near Dani Bada, Raipur Budha Para, Raipur – 492 001 Chhattisgarh [Pan: Agjpg 7698 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri B. Subramanyam, C.A. ""यथ" क" ओर से /Respondent By : Shri S. K. Meena, Cit-D.R. सुनवाई क" तार"ख/Date Of Hearing : 13.09.2023 घोषणा क" तार"ख /Date Of Pronouncement : 02.11.2023

13 of paper book) 1.4. As there was no personal hearing was provided by the Ld. PCIT within reasonable time, further written submission dated 25.02.2022 and 07.03.2022 with necessary evidences were as filed online. (Please refer page no. 9 to 12 of paper book) 1.5. The Ld. PCIT has not accepted the prayer of Appellant to provide for an opportunity

HITESH GOLCHHA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are partly allowed, in terms of our observations herein above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.101, 102, 103 & 104/Rpr/2022 (िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18) V. Hitesh Golchha Acit, Prop. Of Mouli Investment, Central Circle-1 Jeevan Ganga, Near Dani Bada, Raipur Budha Para, Raipur – 492 001 Chhattisgarh [Pan: Agjpg 7698 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri B. Subramanyam, C.A. ""यथ" क" ओर से /Respondent By : Shri S. K. Meena, Cit-D.R. सुनवाई क" तार"ख/Date Of Hearing : 13.09.2023 घोषणा क" तार"ख /Date Of Pronouncement : 02.11.2023

13 of paper book) 1.4. As there was no personal hearing was provided by the Ld. PCIT within reasonable time, further written submission dated 25.02.2022 and 07.03.2022 with necessary evidences were as filed online. (Please refer page no. 9 to 12 of paper book) 1.5. The Ld. PCIT has not accepted the prayer of Appellant to provide for an opportunity

HITESH GOLCHHA,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are partly allowed, in terms of our observations herein above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.101, 102, 103 & 104/Rpr/2022 (िनधा"रण वष" /Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18) V. Hitesh Golchha Acit, Prop. Of Mouli Investment, Central Circle-1 Jeevan Ganga, Near Dani Bada, Raipur Budha Para, Raipur – 492 001 Chhattisgarh [Pan: Agjpg 7698 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri B. Subramanyam, C.A. ""यथ" क" ओर से /Respondent By : Shri S. K. Meena, Cit-D.R. सुनवाई क" तार"ख/Date Of Hearing : 13.09.2023 घोषणा क" तार"ख /Date Of Pronouncement : 02.11.2023

13 of paper book) 1.4. As there was no personal hearing was provided by the Ld. PCIT within reasonable time, further written submission dated 25.02.2022 and 07.03.2022 with necessary evidences were as filed online. (Please refer page no. 9 to 12 of paper book) 1.5. The Ld. PCIT has not accepted the prayer of Appellant to provide for an opportunity

PRIYESH SINGHANIA, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.462/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Priyesh Singhania 730/1, Radha Kunj, Opposite Vip Guest House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 Pan: Aoups7838A ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 PAN: AOUPS7838A ........अपीलाथ" / Appellant बनाम / V/s. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent Assessee by : Shri Mahendra Kumar Agrawal, CA Revenue by : Dr. Priyanka Patel, Sr. DR सुनवाई क" तार"ख / Date of Hearing : 17.09.2025 घोषणा क" तार"ख / Date of Pronouncement : 18.09.2025 2 Priyesh Singhania

CHHATTISGARH STATE POWER GENERATION CO. LTD.,RAIPUR vs. DY. COMMISSIONER OF INCOME TAX-1(1), RAIPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.16/Rpr/2017 "नधा"रण वष" / Assessment Year : 2009-10 Chhattisgarh State Power Generation Company Ltd. O/O. Executive Director-Finance Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.24/Rpr/2022 "नधा"रण वष" / Assessment Year : 2018-19 Chhattisgarh State Power Generation Company Ltd. Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S.

properties and liabilities may not be transferred; there may not be any consideration for demerger by way of issue of shares; the transfer may not be on going concern basis, etc. **** 6.2 The Act, therefore, amends Explanation 4 to provide that such splitting up or reconstruction shall be subject to conditions as may be specified by the Central Government