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.

reassess such income and also any other income chargeable to tax which comes to his notice subsequently in the course of the proceedings under thus section or recompute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereinafter in the section 148 to 153 referred to as the relevant

ANIL NACHRANI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BHOPAL, BHOPAL

The appeal of the assessee is allowed, in terms of our aforesaid observations

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 47/Rpr/2022) (Assessment Year: 2012-13)

b) The Learned PCIT (Central), Bhopal issued notice u/s 263, copy of the notice dated 14.01.2022 is placed on Page No 16 to 18 of the Paper Book. The Learned PCIT could not have assumed jurisdiction u/s 263 in respect of non-Est proceedings which was vitiated by the vice of non- issuance of mandatory notice u/s

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

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

4,76,32,950/- u/s. 54B of the Act was not found in order. Elaborating on his view, the Pr. CIT observed that the pre-condition for claim of deduction u/s. 54B. i.e. the subject land transferred by the assessee was during the period of two years immediately preceding the date of transfer was being used by the assessee

ARUNA TIWARI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 90/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Aruna Tiwari 762, Sundar Nagar, Raipur (C.G.)-492 001 Pan: Adbpt4977B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent

b) of sub-section (4) of section 120 to exercise or perform all or any of the powers and functions conferred on, or assigned to, an assessing officer under this Act. In the instant case, the order of assessment was challenged on several grounds and, particularly, on the ground that no notice under section

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)

120/- and claimed a refund of Rs.1,80,860/-. Meanwhile, the case of the assessee was transferred to ReAC(AU) on 08.12.2021. A letter and notices u/s 142(1), along with a questionnaire, were issued to the assessee on 27.12.2021, but the assessee remained non-responsive towards the same. Further, the assessee remain non- responsive towards the notices dated

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)

120/- and claimed a refund of Rs.1,80,860/-. Meanwhile, the case of the assessee was transferred to ReAC(AU) on 08.12.2021. A letter and notices u/s 142(1), along with a questionnaire, were issued to the assessee on 27.12.2021, but the assessee remained non-responsive towards the same. Further, the assessee remain non- responsive towards the notices dated

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved

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 )

120 6,952 11.10 2013-14 153A/143(3) 17597520 16,25,000 11.12 1,98,10,941 1,98,10,940 5,88,421 11.9 2014-15 143(3) 25060 17,91,475 11.3 2,26,65,058 2,26,65,060 3,07,790 11.5 69,33,535 11.6.1 65,00,000 11.7.1 71,07,198 11.8 9. Aggrieved