INCOME TAX OFFICER, WARD-1(4), RAIPUR vs. MESERS G P INFRAVENTURES, RAIPUR

The appeal of the department stands disposed off

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

D E R Per Arun Khodpia, AM: The captioned cross appeals filed by the department and the assessee are directed against the order of Commission Income Tax (Appeal), Raipur, dated 09.03.2020 for the Assessment Year 2015-16, which in turn result from the order u/s 143(3) passed by the Income Tax Officer, ward-1(4), Raipur, C.G. dated

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. SHRI VINAY AGRAWAL, MAHASAMUND

The appeal of the revenue stands dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 29 & 30/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15, 2015-16)

27, 2021 issued by the Central Government under Section 3(1) of TOLA, 2020 contained an explanation declaring that the provisions under the old regime shall apply to the reassessment proceedings initiated under them, therefore, the A.Os had accordingly issued reassessment notices between April 1, 2021 and June 30, 2021 by relying on the provisions under Section

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. SHRI VINAY AGRAWAL, MAHASAMUND

The appeal of the revenue stands dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 29 & 30/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15, 2015-16)

27, 2021 issued by the Central Government under Section 3(1) of TOLA, 2020 contained an explanation declaring that the provisions under the old regime shall apply to the reassessment proceedings initiated under them, therefore, the A.Os had accordingly issued reassessment notices between April 1, 2021 and June 30, 2021 by relying on the provisions under Section

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

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

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)

27, 2021 issued by the Central Government under Section 3(1) of TOLA, 2020 contained an explanation declaring that the provisions under the old regime shall apply to the reassessment proceedings initiated under them, therefore, the A.Os had accordingly issued 13 Kamlesh Kukreja Vs. ITO, Ward-1(1), Raipur reassessment notices between April 1, 2021 and June

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

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) ..

reassessment Explanation.-In this section, "Valuation Officer" has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957) On careful reading of amended provision, it is abundantly clear that before 01.10.2014, AO was not empowered to make reference to DVO u/s 142A(1) of the Act without expressing his dissatisfaction about

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

D E R Per Bench: The captioned appeals by the assessee are instituted to assail the orders of Commissioner of Income Tax (Appeals), Raipur-3 [in short “Ld. CIT(A)”], passed under section 250 of the Income Tax Act, 1961 (in short “the Act”) Assessment Years (AY) from 2008-09 to 2014-15, which in turn arises from the common

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

D E R Per Bench: The captioned appeals by the assessee are instituted to assail the orders of Commissioner of Income Tax (Appeals), Raipur-3 [in short “Ld. CIT(A)”], passed under section 250 of the Income Tax Act, 1961 (in short “the Act”) Assessment Years (AY) from 2008-09 to 2014-15, which in turn arises from the common

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

D E R Per Bench: The captioned appeals by the assessee are instituted to assail the orders of Commissioner of Income Tax (Appeals), Raipur-3 [in short “Ld. CIT(A)”], passed under section 250 of the Income Tax Act, 1961 (in short “the Act”) Assessment Years (AY) from 2008-09 to 2014-15, which in turn arises from the common

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

D E R Per Bench: The captioned appeals by the assessee are instituted to assail the orders of Commissioner of Income Tax (Appeals), Raipur-3 [in short “Ld. CIT(A)”], passed under section 250 of the Income Tax Act, 1961 (in short “the Act”) Assessment Years (AY) from 2008-09 to 2014-15, which in turn arises from the common

SHARDA STEEL TRADERS, RAIPUR,RAIPUR vs. ACIT/DCIT, CENTRAL CIRCLE-2, RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 111, 112, 113, 114, 115 & 116/Rpr/2025 (िनधा"रण वष" Assessment Years: 2008-09, 2009-10, 2010-11,2011-12, 2012-13, 2014-15 )

D E R Per Bench: The captioned appeals by the assessee are instituted to assail the orders of Commissioner of Income Tax (Appeals), Raipur-3 [in short “Ld. CIT(A)”], passed under section 250 of the Income Tax Act, 1961 (in short “the Act”) Assessment Years (AY) from 2008-09 to 2014-15, which in turn arises from the common