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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

u/s 271(1)(c) of the Act was liable to be 29 South Eastern Coalfields Group of cases (On penalty) vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

SMT. DIPALBEN MANISH PATEL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD 2(1), RAIPUR, RAIPUR

In the result, the assessee's appeal is allowed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 215/Rpr/2023 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Dipalben Manish Patel 4-502, Near Maharashtra Mandal, Choubey Colony, Raipur (C.G.)-492 001 Pan : Alupp3271B

u/s 271(1)(c) of the Act was liable to be vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) as well as the ITAT

VIKAS SHARMA, DURG,DURG vs. INCOME TAX OFFICER-1(2), BHILAI, DURG

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 256/Rpr/2023 "नधा"रण वष" / Assessment Year : 2015-16 Vikas Sharma Quarter No.6-A, Ruabandha Sector, Bhilai, Dist. Durg (C.G.)-490 006 Pan : Ddcps1720P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Bhilai, Durg (C.G.) ……""यथ" / Respondent

u/s 271(1)(c) of the Act was liable to be vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) as well as the ITAT

PRASHANT MANOHAR BHAGWAT, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 86/Rpr/2023 "नधा"रण वष" / Assessment Year : 2014-15 Prashant Manohar Bhagwat H. No.11, South Avenue, Choubey Colony, Raipur (C.G.)-492 001 Pan : Ahfpb6105K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent

u/s 271(1)(c) of the Act was liable to 14 Prashant Manohar Bhagwat Vs. ITO-1(2), Raipur be vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions

KHOMRAM CHANDRAWANSHI (HUF), ,RAIPUR vs. INCOME TAX OFFICER-4(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 165/Rpr/2022 "नधा"रण वष" / Assessment Year : 2014-15 Khomram Chandrawanshi (Huf) House No.18, Ring Road Chowk, Krishnasakha Society, Rohinipuram, Raipur-492 001 (C.G) Pan : Aakhk2082E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-4(1), Raipur (C.G.) ……""यथ" / Respondent

u/s 271(1)(c) of the Act was liable to be vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) 14 Khomram Chandrawanshi

ASHOK KUMAR SINGH, DURG,DURG vs. INCOME TAX OFFICER-2(2), BHILAI, DURG

In the result, the assessee's appeal is allowed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 150/Rpr/2023 "नधा"रण वष" / Assessment Year : 2010-11 Ashok Kumar Singh P-10, Rishab Green City, Pulgaon, Durg-491 001 (C.G) Pan : Bcfps1394K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(2), Bhilai (C.G.) ……""यथ" / Respondent

u/s 271(1)(c) of the Act was liable to be vacated. For the sake of clarity the observations of the Hon’ble High Court of Bombay in its aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) as well as the ITAT

NILIMA AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.126/Rpr/2025 "नधा"रण वष" / Assessment Year : 2015-16 Nilima Agrawal E-5, Sector-1, Devendra Nagar, Raipur (C.G.)-492 001 Pan: Afepa5240B ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

u/s. 271(1)(c) of the Act in the case of the assessee was not valid. 5. That on similar facts and circumstances regarding ambiguity in the notice issued for penalty u/s.271(1)(c) of the Act, the Hon’ble High Court of Bombay in the case of Pr. CIT Vs. Times Global Broadcasting Ltd. (2025) 172 taxmann.com

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR vs. CHHATTISGARH STATE POWER DISTRIBUTION COMPANY LTD., RAIPUR, RAIPUR

In the result ground 2 of the CO

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकरअपीलसं./Ita No.181/Rpr/2023 (Ay-2010-2011) आयकरअपीलसं./Ita No. 182/Rpr/2023 (Ay:2011-2012) आयकरअपीलसं. /Ita No. 183/Rpr/2023(Ay: 2012-2013) आयकरअपीलसं. /Ita No. 184/Rpr/2023(Ay: 2013-2014) आयकरअपीलसं./Ita No. 185/Rpr/2023(Ay: 2014-2015) आयकरअपीलसं./Ita No. 186/Rpr/2023(Ay: 2015-2016) आयकरअपीलसं./Ita No. 187/Rpr/2023(Ay: 2017-2018) आयकरअपीलसं. /Ita No. 188/Rpr/2023(Ay: 2018-2019) Deputy Commissioner Of Income Tax, V Chhattisgarh State Power Distribution Circle-1(1), Raipur S Company Limited, Aayakar Bhawan, Civil Lines, Raipur Vidhyut Seva Bhawan, Daganiya, Raipur Pan: Aadcc6047K & Cross Objection No. 10/Rpr/2023 (2011-12) Cross Objection No. 11/Rpr/2023 (2012-13) Cross Objection No. 12/Rpr/2023 (2014-15) Cross Objection No. 13/Rpr/2023 (2015-16) Cross Objection No. 14/Rpr/2023 (2018-19) Chhattisgarh State Power Distribution V Deputy Commissioner Of Income Tax, Company Limited, Circle-1(1), Raipur S Vidhyut Seva Bhawan, Aayakar Bhawan, Civil Lines, Raipur Daganiya, Raipur Pan: Aadcc6047K (अपीलाथ"/Applicant) (""यथ" / Respondent) : िनधा"रतीक"ओरसे /Assessee By : Shri Praveen Khandelwal & Praveen Goyal, Ca'S राज"वक"ओरसे /Revenue By : Shri Debashish Lahiri, Cit-Dr सुनवाईक"तार"ख/ Date Of Hearing : 24.11.2023 घोषणाक"तार"ख/Date Of Pronouncement : 14.12.2023

Penalty proceedings u/s 271(1)(c) of the Act are separately initiated. 4.3 Aggrieved by the aforesaid addition made by the Ld. AO, assessee preferred an appeal before the Ld. CIT(A), wherein the contention of the assessee has been accepted by the Ld. CIT(A) following the judgment of ITAT in Assessee's own case