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

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 2 & 3/Rpr/2023 Co Nos. 19 & 20/Rpr/2023 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

Section 139 of the Act, the same was allowable u/s. 43B(b) of the Act. The Ld. AR submitted that the view of the assessee company at the time of filing the original/revised return of income was duly supported by the judgment of the Hon’ble Supreme Court in the case of Commissioner Of Income Tax Vs. Alom Extrusions Limited

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

SANTOSH JAIN, DURG,DURG vs. INCOME TAX OFFICER-1(1), BHILAI, DURG

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 144, 146 & 148/Rpr/2023 "नधा"रण वष" / Assessment Years : 1993-94, 1994-95 & 1995-96 Santosh Jain Opp. P.N Tiwari, Gandhi Chowk, Durg (C.G.)-491 001 Pan: Afypj6194D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.) ……""यथ" / Respondent

271(1)(b) has nothing to do with the amount of addition/ disallowance made in assessment and the outcome in quantum appeal did not have any bearing upon penalty u/s 277(1)(b). Therefore, sub-clause (a) of section

SANTOSH JAIN, DURG,DURG vs. INCOME TAX OFFICER-1(1), BHILAI, DURG

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 144, 146 & 148/Rpr/2023 "नधा"रण वष" / Assessment Years : 1993-94, 1994-95 & 1995-96 Santosh Jain Opp. P.N Tiwari, Gandhi Chowk, Durg (C.G.)-491 001 Pan: Afypj6194D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.) ……""यथ" / Respondent

271(1)(b) has nothing to do with the amount of addition/ disallowance made in assessment and the outcome in quantum appeal did not have any bearing upon penalty u/s 277(1)(b). Therefore, sub-clause (a) of section

SANTOSH JAIN, DURG,DURG vs. INCOME TAX OFFICER-1(1), BHILAI, DURG

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 144, 146 & 148/Rpr/2023 "नधा"रण वष" / Assessment Years : 1993-94, 1994-95 & 1995-96 Santosh Jain Opp. P.N Tiwari, Gandhi Chowk, Durg (C.G.)-491 001 Pan: Afypj6194D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.) ……""यथ" / Respondent

271(1)(b) has nothing to do with the amount of addition/ disallowance made in assessment and the outcome in quantum appeal did not have any bearing upon penalty u/s 277(1)(b). Therefore, sub-clause (a) of section

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

B), as the deeming provisions, create a legal fiction as to the grounds for penalty proceedings. Indeed, the Apex Court in CIT v. Atul Mohan Bindal [ 73], has explained the scope of section 271(1)(c) thus: “[Explanation 1, appended to section 27(1) provides that if that person fails to offer an explanation or the explanation offered