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)

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA. All notices issued beyond the surviving period are time barred and liable to be set aside;" 22. Shri Ravi Agrawal, Ld. AR for the assessee, after referring to the post-amended Section 148 r.w.s. 148A r.w.s

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

reassessment procedure u/s 147 to 151, w.e.f 01.04.2021. Thus, the old regime of re-assessment ended on 31.03.2021 and the new regime of re-assessment started from 01.04.2021. Due to COVID-19, the Government introduced the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA), extending time limits. Accordingly, the time available for the Department to issue notice

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

reassessment procedure u/s 147 to 151, w.e.f 01.04.2021. Thus, the old regime of re-assessment ended on 31.03.2021 and the new regime of re-assessment started from 01.04.2021. Due to COVID-19, the Government introduced the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA), extending time limits. Accordingly, the time available for the Department to issue notice

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

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

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 )

147 of the Act to reopen an assessment only after due application of mind. If for some reason, there is an error that creeps into this exercise by the AO, then the law expects the superior officer to be able to correct that error. This explains why Section 151 (1) requires an officer of the rank of the Joint Commissioner

SOUTH EASTERN COALFIELDS LIMITED, BILASPUR,BILASPUR vs. ASSISSTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), BILASPUR, BILASPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 43/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

147 except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA or section 150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section

SOUTH EASTERN COALFIEDS LIMITED,BILASPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, BILASPUR

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 314/Rpr/2023 "नधा"रण वष" / Assessment Year : 2017-18 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

147 except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA or section 150; 11 M/s. South Eastern Coalfields Limited Vs. ACIT, Circle-1(1), Bilaspur (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions

NEELAM RAI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), BILASPUR, BILASPUR

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: 97/Rpr/2025 (िनधा"रण वष" Assessment Year: 2016-17)

147 of the I.T. Act after obtaining necessary approval. Accordingly, notice u/s 148 was issued on 26.03.2023. Further, various opportunities were granted to the assessee to furnished explanation and necessary information to complete the assessment, however, the assessee remain non-compliant at every stage of the assessment proceedings. Finally, the Ld. AO, in absence of any explanation by the assessee

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