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 under this Act, where the estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A

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 under this Act, where the estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A

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 under this Act, where the estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A

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 under this Act, where the estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A

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 under this Act, where the estimate of the value of any investment referred to in section 69 or section 69B or the value of any bullion, jewellery or other valuable article referred to in section 69A

POLICE WELFARE SOCIETY, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, WARD- RAJNANDGAON, RAJNANDGAON

Appeal stands allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 255 & 256/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18, 2018-19)

reassessment proceedings null and void in light of judicial precedents made by the Honorable Courts and Tribunal. Ground No. 6. That the learned Commissioner of Income Tax (Appeals) NFAC ought to have admitted additional grounds of appeal raised by the assessee since they pertain to pure questions of law and do not require fresh evidence. Ground No. 7. The appellant

POLICE WELFARE SOCIETY, RAJNANDGAON,RAJNANDGAON vs. INCOME TAX OFFICER, WARD- RAJNANDGAON, RAJNANDGAON

Appeal stands allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 255 & 256/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18, 2018-19)

reassessment proceedings null and void in light of judicial precedents made by the Honorable Courts and Tribunal. Ground No. 6. That the learned Commissioner of Income Tax (Appeals) NFAC ought to have admitted additional grounds of appeal raised by the assessee since they pertain to pure questions of law and do not require fresh evidence. Ground No. 7. The appellant

RASHI STEEL AND POWER LIMITED,BILASPUR vs. ACIT, NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No. 73/Rpr/2021 (Assessment Year: 2012-13) M/S Rashi Steel & Power Ltd. Vs Acit Cf9, Rajeev Plaza, Bilaspur New Delhi Pan No. :Aaecr 6450 Q : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 01/06/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

69A mandates addition only 3 in case the assessee is found to be owner of money, bullion etc. not recorded in the books of account. 12. That the Learned CIT(A) has erred both in law and facts of the case in confirming the addition of Rs.85,00,000/- in the hands of the appellant due to misinterpretation of section

RANJEET SINGH SAINI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(1), RAIPUR, RAIPUR

Appeal of the assessee is partly allowed for statistical purposes, in terms of over aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 58/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

reassessment proceedings may kindly be held to be illegal and consequential enhancement of Rs.1,14,88,500/- made to the total income may kindly be directed to be deleted. 4. On the facts and circumstances of the case and in law, the Assessment order passed is illegal, bad-in-law and void-ab-initio inasmuch as the assessment proceedings were

LOKESHWAR KUMAR SAHU,DHAMTARI vs. INCOME TAX ASSESSING OFFICER, DHAMTARI

The appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.510/Rpr/2025 िनधा"रण वष" /Assessment Year: 2014-15 Lokeshwar Kumar Sahu, Shri Balaji Construction Co. Near Rest House Kathuriya Complex, Ratnabandha Road, Dhamtari, Chhattisgarh. Pan: Ctnps5629H .......अपीलाथ" / Appellant बनाम / V/S.

reassessment proceedings were initiated on a protective basis, which is not legally valid, and erroneously treated the same as substantive, thereby uploading an assessment that lacked jurisdiction from the outset. 3. That the learned CIT(A) erred in sustaining the addition of ?3,50,000 under section 69A

SOURABH AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.735/Rpr/2025 िनधा"रण वष" /Assessment Year: 2019-20 Sourabh Agrawal, Prop. Sawaria Traders, Shop No.217, Samta Colony, Raipur, Chhattisgarh. Pan: Appa0229M .......अपीलाथ" / Appellant बनाम / V/S.

69A of the Act. 5. Be that as it may, considering the spectrum of facts in this case, wherein an ex-parte order has been passed in spite of the opportunities given to the assessee and when the Department has not brought out any deliberate or malafide conduct on the part of the assessee not responding to the hearing notices

NELSON YONA,RAIPUR vs. INCOME TAX OFFICER, WARD 4(1), RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.181/Rpr/2025 "नधा"रण वष" /Assessment Year : 2011-12 Nelson Yona Near Shiv Mandir, Avanti Vihar, Raipur (C.G.)-492 006 Pan: Adbpy8725E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Ward-4(1), Raipur (C.G.) ……""यथ" / Respondent

69A of the Act and not Section 68 as had been invoked by the A.O. 6. Be that as it may, it is also noted at Para 5.1 of the Ld. CIT(Appeals)/NFAC that an ex-parte order has been passed by the said authority due to non-compliance by the assessee. For the sake of completeness, Para

KANTI LAL DUGGAD, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-4(1), RAIPUR, RAIPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of the aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No.141/Rpr/2023 "नधा"रण वष" / Assessment Year : 2017-18 Kanti Lal Duggad 35/1008, Rms Colony, Tagore Nagar, Raipur (C.G.)-492 001 Pan : Agapd7948J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-4(1), Raipur (C.G.). ……""यथ" / Respondent

Reassessment Order may please be quashed and cancelled on this ground alone. 3 Kanti Lal Duggad Vs. ITO, Ward-4(1), Raipur 3. GROUND NO. III On the facts and in the circumstances of the case as well as in law, the Ld.CIT(A) has grossly erred in confirming the addition of Rs.33,00,000/- on account of cash deposits

DAMANJEET SINGH OBEROI, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Damanjeet Singh Oberoi Dcit, Circle 1(1), Raipur C/O Oberoi Tour & Travels, Shop No.1, Wali Mohd. Vs. Building, Kk Road, Moudhapara, Raipur – 492001 Pan: Aaepo3096L (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

69A of the Act. We find the Ld. CIT(A) / NFAC upheld the re-assessment proceedings as well addition on merit. Under these circumstances, we have to see as to whether the notice issued u/s 148 of the Act for the assessment year 2015-16 on 26.07.2023 is a valid notice or not. 11. We find an identical issue

SUKHDEV SINGH JOSHI ,JAGDALPUR, BASTAR vs. INCOME TAX OFFICER, WARD, JAGDALPUR, JAGDALPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 173 & 174/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

reassessment proceedings initiated by Ld. Assessing Officer without following standard procedure mandated by CBDT through its binding letter dated 10/01/2018. 5. In facts and circumstances of the case and in law, the ld. Commissioner of Income-tax (Appeals), NFAC has erred in confirming the addition of Rs.81,89,400 as unexplained income under section 69A

SUKHDEV SINGH JOSHI,JAGDALPUR, BASTAR vs. INCOME TAX OFFICER, WARD, JAGDALPUR, JAGDALPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 173 & 174/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

reassessment proceedings initiated by Ld. Assessing Officer without following standard procedure mandated by CBDT through its binding letter dated 10/01/2018. 5. In facts and circumstances of the case and in law, the ld. Commissioner of Income-tax (Appeals), NFAC has erred in confirming the addition of Rs.81,89,400 as unexplained income under section 69A

AMIT KUMAR CHHABRIYA, RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeal of the assessee is allowed for statistical purposes, in terms of over aforesaid observations

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 150/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20)

69A as unexplained money of the assessee and is liable to be taxed in accordance with provisions of section 115BBE of the Act. 4. Aggrieved with the aforesaid addition, the assessee preferred an appeal before the Ld. CIT(A), wherein the assessee remain absent in compliance to the notices of hearing and opportunities granted by the Ld. CIT(A). Accordingly

SUDHA GUPTA,BILASPUR vs. THE INCOME TAX OFFICER, BILASPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 435/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

69A which applies on unaccounted a valuable articles, whereas in present case cash deposit was properly recorded in Cash book maintained by the assessee. 7. Ld. CIT(A) erred in confirming AO’s act of initiation of Penalty under Sec 270A on rental Income of Rs. 1459564/- which was already declared in ITR filed. 8. Ld. CIT(A) erred