INCOME TAX OFFICER-1(1), BILASPUR vs. MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD. , BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin

MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD., BILASPUR,BILASPUR vs. INCOME TAX OFFICER, WARD-1(1), BILASPUR, BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

reassessment under Sections 139, 147, 148, 149, 151 & 153. 28. The language of explanation 2 to new Section 148 is akin

KAMLESH KUKREJA, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 379/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16)

reassessment under Sections 147 to 151 of the Income Tax Act w.e.f 1st April 2021. Broadly speaking, the changes made available on the statute by the legislature in all its wisdom are, viz. (i) Section 148

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

VIDYA SHANKER JAISWAL, SARGUJA,SARGUJA vs. ITO, WARD-2, AMBIKAPUR, AMBIKAPUR

The appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.141 & 142/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

MOHAMMED USMAN, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.180/Rpr/2026 "नधा"रण वष" /Assessment Year : 2011-12 Mohammed Usman C/25, Nandini Road, Power House, Bhilai-490 011, Dist. Durg Pan: Aafpu9292H

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the 7 Mohammed Usman Vs. ITO-2(1), Bhilai (C.G.) assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

SATYA ENTERPRISES,BILASPUR vs. INCOME TAX OFFICER, WARD-1(2), BILASPUR, BILASPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.396/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Satya Enterprises Ward No.3, Shanti Nagar, Bilaspur (C.G.)-495 001 Pan: Adcfs1415L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bilaspur (C.G.) ……""यथ" / Respondent

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

MARUTI CLEAN COAL AND POWER LTD.,RAIPUR vs. PR. COMMISIONER INCOME TAX-1, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 55/Rpr/2021 "नधा"रण वष" / Assessment Year : 2011-12 Maruti Clean Coal & Power Ltd. Ward No.42, Building No.14, Civil Lines, Near Income Tax Colony, Chhattisgarh-492 001. Pan : Aadcm4810C .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent Assessee By :Shri Salil Kapoor, Ms. Ananya Kapoor & Ms. Soumya Singh, Advocates. Revenue By :Shri P. K Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 05.08.2022 घोषणा क" तार"ख / Date Of Pronouncement : 31.10.2022

148 of the Act, dated 28.03.2018. It is the claim of the ld. A.R that as the A.O had exceeded his jurisdiction and reopened the concluded assessment and passed the reassessment order under Sec. 143(3) r.w.s 147, dated 30.12.2018, therefore, such invalid order of reassessment could not have been revised by the Pr. CIT under

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

sections 148 to 153, assess or reassess" such" income "and also any other income chargeable to tax which has escaped

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

sections 148 to 153, assess or reassess" such" income "and also any other income chargeable to tax which has escaped

EARTHSTAHL & ALLOYS LTD., RAIPUR,RAIPUR vs. INCOME TAX OFFICER, 3(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.478/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Earthstahl & Alloys Limited 5B Mohini Merline, Jayshree Vihar Pandritarai Mandi Gate, Ravigram S.O, Raipur-492 001 (C.G.) Pan: Aacce3567F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-3(1), Raipur (C.G.) ……""यथ" / Respondent

sections 148 to 153, assess or reassess" such" income "and also any other income chargeable to tax which has escaped

RAHUL BAJPAI,IDGAH CHOWK vs. ACIT CIRCLE 1(1), SHRI RAM PLAZA

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.348/Rpr/2023 "नधा"रण वष" / Assessment Year: 2014-15 Rahul Bajpai Idgah Chowk, Bilaspur Chhattisgarh-495 001 Pan: Aexpb4410L .......अपीलाथ" / Appellant बनाम / V/S.

reassessment proceedings validly. Hence, the contentions of appellant are rejected. 12 Rahul Bajpai Vs. ACIT, Circle-1(1), Bilaspur 6.6. The assessee contends that copy of approval was not supplied to him by the officer. The assessment order indicates that the approval was obtained by the A.O. before initiation of proceedings under section 147 read with section 148

INCOME TAX OFFICER-1(2), RAIPUR vs. KANHA GRAIN PROCESS, RAIPUR

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

Section 148, both dated 5th April 2022 (Exhibit B and C); (ii) the reassessment order dated 27th May 2024 passed

SMT. ANITA BANODHA ALIAS ANITA KATHGAR , ANITA AUTO, PONDI CHIRMIRI KOREA,KOREA vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, appeal of the assessee is dismissed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.230/Rpr/2025 "नधा"रण वष" / Assessment Year : 2018-19 Smt. Anita Banodha Alias Anita Kathgar Anita Auto, Pondi, West Chirmiri, Korea (C.G)-497 449 Pan: Afgpj1876C ........अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1(C.G.) ……""यथ" / Respondent

Section 148A of the Act as was there vide the Finance Act, 2021 w.e.f. 01.04.2021 as applicable to the case of the assessee and the same reads as follows: 3 Smt. Anita Banodha alias Anita Kathgar Vs. Pr. CIT, Raipur-1 “148. Issue of notice where income has escaped assessment- Before making the assessment, reassessment

HARJEET SINGH CHHABRA, RAIPUR,RAIPUR vs. ITO, WARD-1, RAIPUR (ERST. ITO-1(3), RAIPUR), RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.469/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Harjeet Singh Chhabra H. No.84, Las Vista, Mahaveer Nagar, Raipur (C.G.)-492 001 (C.G.) Pan: Adkpc0408P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Central Circle-1, Raipur (C.G.) ……""यथ" / Respondent

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

ANIL KUMAR PAREKH, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD DHAMTARI, DHAMTARI

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.194/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Anil Kumar Parekh C/O. Madhu Traders, Station Road, Dhamtari (C.G.)-493 773 Pan: Akepp0240E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Dhamtari (C.G.) ……""यथ" / Respondent

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

RAMA AGRAWAL, DURG,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.490/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Rama Agrawal 33A, I. E. Bhilai, S.O Industrial Estate, Durg-490 026 (C.G.) Pan: Acgpa8359N

reassessment proceedings. The fact that on the notice issued under section 143(2) of the Act, the assessee had placed its objection and reiterated its earlier return filed as one filed in response to the notice issued under section 148

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL-1), RAIPUR, RAIPUR vs. M/S SUNIL SPONGE PVT. LTD., RAIPUR

In the result, the appeal of the revenue is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.73/Rpr/2022 "नधा"रण वष" / Assessment Year : 2007-08 The Deputy Commissioner Of Income Tax, (Central Circle)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Sunil Sponge Pvt. Ltd. H. No.11, Jalvihar Colony, Raipur (C.G.)-492 001 (C.G.) Pan : Aahcs7999A ……""यथ" / Respondent

reassessment, for that assessment year. Section 149 of the Act deals with the time limit for notice under section 148