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) ..

house, Tribunal was justified in deleting additions made by Assessing Officer on account of unexplained investment in construction - Held, yes (4) ClT VS. Manoj Jain 287 ITR 285(Delhi)- Section 158BC of the Income-tax Act, 1961 - Block assessment in search cases - Procedure for - Tribunal having found as a fact that search on assessee's premises did not lead

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) ..

house, Tribunal was justified in deleting additions made by Assessing Officer on account of unexplained investment in construction - Held, yes (4) ClT VS. Manoj Jain 287 ITR 285(Delhi)- Section 158BC of the Income-tax Act, 1961 - Block assessment in search cases - Procedure for - Tribunal having found as a fact that search on assessee's premises did not lead

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) ..

house, Tribunal was justified in deleting additions made by Assessing Officer on account of unexplained investment in construction - Held, yes (4) ClT VS. Manoj Jain 287 ITR 285(Delhi)- Section 158BC of the Income-tax Act, 1961 - Block assessment in search cases - Procedure for - Tribunal having found as a fact that search on assessee's premises did not lead

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) ..

house, Tribunal was justified in deleting additions made by Assessing Officer on account of unexplained investment in construction - Held, yes (4) ClT VS. Manoj Jain 287 ITR 285(Delhi)- Section 158BC of the Income-tax Act, 1961 - Block assessment in search cases - Procedure for - Tribunal having found as a fact that search on assessee's premises did not lead

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

200 (SC)1: (refer page no. 135 to 145 of paper book) Wherein it was held by the Hon'ble Apex Court that "what is contemplated by Section 263 is an opportunity of hearing to be afforded to the Assessee. Failure to give such an opportunity would render the revisional order legally fragile not on the ground of lack

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

200 (SC)1: (refer page no. 135 to 145 of paper book) Wherein it was held by the Hon'ble Apex Court that "what is contemplated by Section 263 is an opportunity of hearing to be afforded to the Assessee. Failure to give such an opportunity would render the revisional order legally fragile not on the ground of lack

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

200 (SC)1: (refer page no. 135 to 145 of paper book) Wherein it was held by the Hon'ble Apex Court that "what is contemplated by Section 263 is an opportunity of hearing to be afforded to the Assessee. Failure to give such an opportunity would render the revisional order legally fragile not on the ground of lack

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

200 (SC)1: (refer page no. 135 to 145 of paper book) Wherein it was held by the Hon'ble Apex Court that "what is contemplated by Section 263 is an opportunity of hearing to be afforded to the Assessee. Failure to give such an opportunity would render the revisional order legally fragile not on the ground of lack

KAMLESH JAIN & SONS HUF,RAIPUR vs. INCOME TAX OFFICER-3(2), RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri N.K. Choudhryassessment Year: 2016-17

200 (SC) - Venkat Naicken Trust vs. ITO (2000) 242 ITR 141 (Mad) 8. To expound the factual position, it was also pointed out that notice dated 10.03.2021 calling for hearing on 15.03.2021 was eventually signed by the PCIT on 15.03.2021 i.e. on the date of hearing fixed in this regard. Interestingly, notice was signed at 1.49 P.M. whereas the hearing

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

property and to contract by the said name. Further, the appellant is enacted under the State Act for the purpose of taking measures to deal with and satisfying the need of housing accommodation in the State of Chhattisgarh, especially to the lower income group (LIG) and to the weaker sections of the society with a no profit/loss objective. The appellant

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

property and to contract by the said name. Further, the appellant is enacted under the State Act for the purpose of taking measures to deal with and satisfying the need of housing accommodation in the State of Chhattisgarh, especially to the lower income group (LIG) and to the weaker sections of the society with a no profit/loss objective. The appellant

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

property and to contract by the said name. Further, the appellant is enacted under the State Act for the purpose of taking measures to deal with and satisfying the need of housing accommodation in the State of Chhattisgarh, especially to the lower income group (LIG) and to the weaker sections of the society with a no profit/loss objective. The appellant

CHHATTISGARH HOUSING BOARD,RAIPUR vs. EXEMPTION CIRCLE, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

property and to contract by the said name. Further, the appellant is enacted under the State Act for the purpose of taking measures to deal with and satisfying the need of housing accommodation in the State of Chhattisgarh, especially to the lower income group (LIG) and to the weaker sections of the society with a no profit/loss objective. The appellant

CHHATTISGARH HOUSING BOARD,RAIPUR vs. ASSISTANT COMMISSIONER, EXEMPTION CIRCLE,, RAIPUR

In the result, this appeal of the assessee is allowed as above for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

property and to contract by the said name. Further, the appellant is enacted under the State Act for the purpose of taking measures to deal with and satisfying the need of housing accommodation in the State of Chhattisgarh, especially to the lower income group (LIG) and to the weaker sections of the society with a no profit/loss objective. The appellant

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

house property has been decided in quite a few cases. Sec 194-I puts obligation of person paying rent to make TDS from the rent payment. Rent in the impugned provision is defined as payment by whatever name called under any lease, sub-lease, tenancy or any other agreement or arrangement for the use of any machinery, plant or equipment

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

house property has been decided in quite a few cases. Sec 194-I puts obligation of person paying rent to make TDS from the rent payment. Rent in the impugned provision is defined as payment by whatever name called under any lease, sub-lease, tenancy or any other agreement or arrangement for the use of any machinery, plant or equipment

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources