SMT. PUSHPA JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SAMPAT LAL JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SMT. TILOTTAMA JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SANJOG JHABAK L/H OF LATE GAUTAM CHAND JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SANKET JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SMT. SUSHILA DEVI JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SANJOG JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

natural justice, clearly exceeding the revisional jurisdiction and not in 5 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 accordance with the provisions of law. It is prayed that the Revision Order passed u/s.263 of the Act may please be cancelled/set-aside on this ground alone. GROUND No. III 3. That the Revision

SMT. PRABHA KHANDELWAL L/H OF LATE OMPRAKASH KHANDELWAL, BHILAI,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, DURG

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 55/Rpr/2023 "नधा"रण वष" / Assessment Year : 2010-11 Late Omprakash Khandelwal (Through Legal Heir:Smt.Prabha Khandelwal) B-107, Surya Residency, Opposite M.J. College Kohka Road, Bhilai(C.G.)-490023 Pan: Anspk3247N .......अपीलाथ" / Appellant बनाम / V/S.

justice. 3 Ostensibly, on a perusal of the records it transpires that the 2. appeal filed by the assessee is barred by limitation by 268 days. As per the application filed by the legal heir of the assessee (since deceased) the impugned delay had occasioned because the assessee, viz. Shri Omprakash Khandelwal (since deceased), a septuagenarian, during the relevant period

PRADEEP KUMAR AGRAWAL, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD-DHAMTARI, DHAMTARI

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

justice. However, the assessee did not submit the details called for till the date of completion of assessment. As the assessee was non-responsive, the case was completed u/s 147 r.w.s. 144 r.w.s. 144B of the I T Act on 26/03/2022, the final conclusion by the Ld. AO was that the credits in bank account of the assessee remained unexplained

PRADEEP KUMAR AGRAWAL, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD-DHAMTARI, DHAMTARI

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

justice. However, the assessee did not submit the details called for till the date of completion of assessment. As the assessee was non-responsive, the case was completed u/s 147 r.w.s. 144 r.w.s. 144B of the I T Act on 26/03/2022, the final conclusion by the Ld. AO was that the credits in bank account of the assessee remained unexplained

PRADEEP KUMAR AGRAWAL, DHAMTARI,DHAMTARI vs. INCOME TAX OFFICER, WARD-DHAMTARI, DHAMTARI

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita Nos: 158, 159 & 160/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16, 2016-17 & 2017-18)

justice. However, the assessee did not submit the details called for till the date of completion of assessment. As the assessee was non-responsive, the case was completed u/s 147 r.w.s. 144 r.w.s. 144B of the I T Act on 26/03/2022, the final conclusion by the Ld. AO was that the credits in bank account of the assessee remained unexplained

INCOME TAX OFFICER, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

u/s 147 r.w.s. 144B on 27.03.2023. The same is impugned here and hence this appeal order. 5.5. The grounds no. 1, 2 and 3 of the appeal are with respect to the addition of Rs.2,04,23,038/- which is the crux of the dispute also; are taken up together as under: “1. The Assessing Officer erred in making addition

INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

u/s 147 r.w.s. 144B on 27.03.2023. The same is impugned here and hence this appeal order. 5.5. The grounds no. 1, 2 and 3 of the appeal are with respect to the addition of Rs.2,04,23,038/- which is the crux of the dispute also; are taken up together as under: “1. The Assessing Officer erred in making addition

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)

147 r.w.s. 144B may kindly be held to be illegal, bad-in-law and consequential enhancement of Rs.1,14,88,500/- made to the total income may kindly be directed to be deleted. 3. On the facts and circumstances of the case, the reassessment proceedings are illegal, bad-in-law and void-ab-initio inasmuch as the reassessment proceedings were

INCOME TAX OFFICER-1(3), BHILAI, BHILAI vs. RAMANDEEP SINGH SOHI, DURG

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.268/Rpr/2025 "नधा"रण वष" /Assessment Year : 2016-17 The Income Tax Officer-1(3), Bhilai (C.G.)

147 r.w.s. 144 r.w.s 144B of the Act on 30-03-2022 by making additions viz. (i) addition on 5 ITO-1(3), Bhilai Vs. Ramandeep Singh Sohi account of bogus LTCG u/s.69A of the Act : Rs.26,41,000/-; and (ii) addition u/s.69C of the Act for commission paid for accommodation entry: Rs.1,32,500/- and determining total income

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

147 is not in the statute w.e.f. 01-04-2021, any order passed under this section will be illegal. 6. In this respect we also rely in the decision of Indore ITAT bench (Jurisdictional bench) in the case of Shri Shiv Narayan Sharma vs. ACIT- 3(1) ITA No.889/Ind/2018 covering various appeals wherein it was held that (attached as Annexure

DCIT-1(1), BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

147 is not in the statute w.e.f. 01-04-2021, any order passed under this section will be illegal. 6. In this respect we also rely in the decision of Indore ITAT bench (Jurisdictional bench) in the case of Shri Shiv Narayan Sharma vs. ACIT- 3(1) ITA No.889/Ind/2018 covering various appeals wherein it was held that (attached as Annexure

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

147 is not in the statute w.e.f. 01-04-2021, any order passed under this section will be illegal. 6. In this respect we also rely in the decision of Indore ITAT bench (Jurisdictional bench) in the case of Shri Shiv Narayan Sharma vs. ACIT- 3(1) ITA No.889/Ind/2018 covering various appeals wherein it was held that (attached as Annexure

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

natural justice as per the afore-stated binding judgments. Therefore, it is not open for the A.O to proceed against 6 Rama Agrawal Vs. ITO-2(1), Bhilai the assessee u/s. 144 of the Act without issuance of notice u/s. 143(2) of the Act. At this stage, I find that Hon’ble Supreme Court in the case