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)

144B is illegal and void-ab-initio, as it was initiated based on search-related information obtained from a third party, attracting Section 153C and not Section 147., since Section 153C excludes the applicability of Section 147 in such cases, the entire proceedings are without jurisdiction and liable to be quashed. 3. The assessment proceedings initiated via notice u/s

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

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

Section 54B of the Act. 9. The Pr. CIT based on the aforesaid facts, held a conviction, that the A.O while framing the reassessment had failed to examine the assessee’s claim for deduction u/s.54B of the Act, which, thus, had rendered the order of reassessment passed by him u/s. 147 r.w.s. 144B

JAIN ENTERPRISES, BHILAI,DURG vs. PCIT, RAIPUR-1, RAIPUR

In the result, appeal of the assessee is dismissed as above

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 187/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Jain Enterprises, Vs Pr. Commissioner Of Income Tax, 87-B, Light Industrial Area, Raipur-1, Central Revenue Building, Bhilai-490026, C.G. Civil Lines, Raipur, 492001, C.G. Pan: Aagfj3469G (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri S. R. Rao, Advocate राज" की ओर से / Revenue By : Shri Ram Tiwari, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against The Order Dated 24.03.2025 Of The Principal Commissioner Of Income Tax, Raipur-1 (‘Pcit’) Passed Under Section 263 Of The Income Tax Act, 1961 (‘Act’).

u/s 142(1) of the Act, the Ld. AO did not find anything adverse, hence he did not draw any 8 Jain Enterprises vs. Pr. CIT, Raipur-1 adverse inference thereon. Accordingly, the assessee, before the Ld. PCIT, questioned the revisionary proceedings initiated under section 263 of the Act as it was a case of change of opinion only

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)

u/s. 147 r.w.s. 144B of the Act, dated 29.04.2023, therefore, no infirmity did emanate from his order. 15. Before proceeding any further, we deem it fit to cull out the substitution of the scheme of the assessment under section 147 to 151 of the Act, as had been made available on the statute vide the Finance Act, 2021 w.e.f

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)

reassessment made u/s147 would be invalid & is liable to be quashed; relied on Shri Ram Singh (2008) (Raj); Prosperous Buildcon (P) Ltd (2023) (Del HC). 3. On the facts and circumstances of the case and in law, reopening u/s 148/147 is invalid as based on borrowed satisfaction of escaped income of Rs.5,95,39,179 on the count of 'deposits

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)

reassessment made u/s147 would be invalid & is liable to be quashed; relied on Shri Ram Singh (2008) (Raj); Prosperous Buildcon (P) Ltd (2023) (Del HC). 3. On the facts and circumstances of the case and in law, reopening u/s 148/147 is invalid as based on borrowed satisfaction of escaped income of Rs.5,95,39,179 on the count of 'deposits

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)

reassessment made u/s147 would be invalid & is liable to be quashed; relied on Shri Ram Singh (2008) (Raj); Prosperous Buildcon (P) Ltd (2023) (Del HC). 3. On the facts and circumstances of the case and in law, reopening u/s 148/147 is invalid as based on borrowed satisfaction of escaped income of Rs.5,95,39,179 on the count of 'deposits

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)

u/s. 147 r.w.s. 144B of the Act, dated 29.04.2023, therefore, no infirmity did emanate from his order. 15. Before proceeding any further, we deem it fit to cull out the substitution of the scheme of the assessment under section 147 to 151 of the Act, as had been made available on the statute vide the Finance Act, 2021 w.e.f

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)

u/s. 147 r.w.s. 144B of the Act, dated 29.04.2023, therefore, no infirmity did emanate from his order. 15. Before proceeding any further, we deem it fit to cull out the substitution of the scheme of the assessment under section 147 to 151 of the Act, as had been made available on the statute vide the Finance Act, 2021 w.e.f

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 has been completed u/s. 147 r.w.s. 144B of the Act but the ratio of the said judgment regarding non-service of notice u/s. 143(2) of the Act applies also to the facts of the assessee’s case. For the sake of clarity, the relevant observation of the Hon’ble Supreme Court is culled out as follows

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 has been completed u/s. 147 r.w.s. 144 r.w.s 144B of the Act but the ratio of the said judgment regarding non-service of notice u/s. 143(2) of the Act applies also to the facts of the assessee’s case. For the sake of clarity, the relevant observation of the Hon’ble Supreme Court is culled out as follows

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 has been completed u/s. 147 r.w.s. 144B of the Act but the ratio of the said judgment 9 Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur (C.G.) ITA Nos. 141 & 142/RPR/2026 regarding non-service of notice u/s. 143(2) of the Act applies also to the facts of the assessee’s case. For the sake of clarity, the relevant

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 has been completed u/s. 147 r.w.s. 144B of the Act but the ratio of the said judgment 9 Vidya Shankar Jaiswal Vs. ITO, Ward-2, Ambikapur (C.G.) ITA Nos. 141 & 142/RPR/2026 regarding non-service of notice u/s. 143(2) of the Act applies also to the facts of the assessee’s case. For the sake of clarity, the relevant