M/S CMDC ICPL COAL LIMITED,RAIPUR (CG) vs. THE INCOME TAX OFFICER, 3(1), RAIPUR (CG)

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita Nos. 348, 349 & 350/Rpr/2016 "नधा"रण वष" / Assessment Years : 2009-10, 2010-11 & 2012-13 Cmdc Icpl Coal Limited House No.382, Sunder Nagar, Raipur-492 013 (C.G.) Pan : Aadcc4374P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer 3(1), Raipur (C.G.) ……""यथ" / Respondent Assessee By : Shri R.B Doshi, Ca Revenue By : Shri G.N Singh, Dr

section 147 of the Act. It was submitted by the Ld. AR, that now when the reassessment proceedings have been embarked upon by the Assessing Officer on the basis of a mere ‘change of opinion’, therefore, the consequent assessment framed by him vide his order passed u/s. 143(3) r.w.s 147, dated 20.03.2015 could not be sustained and was liable

M/S CMDC ICPL COAL LIMITED,RAIPUR (CG) vs. THE INCOME TAX OFFICER, 3(1), RAIPUR (CG)

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita Nos. 348, 349 & 350/Rpr/2016 "नधा"रण वष" / Assessment Years : 2009-10, 2010-11 & 2012-13 Cmdc Icpl Coal Limited House No.382, Sunder Nagar, Raipur-492 013 (C.G.) Pan : Aadcc4374P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer 3(1), Raipur (C.G.) ……""यथ" / Respondent Assessee By : Shri R.B Doshi, Ca Revenue By : Shri G.N Singh, Dr

section 147 of the Act. It was submitted by the Ld. AR, that now when the reassessment proceedings have been embarked upon by the Assessing Officer on the basis of a mere ‘change of opinion’, therefore, the consequent assessment framed by him vide his order passed u/s. 143(3) r.w.s 147, dated 20.03.2015 could not be sustained and was liable

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

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) ..

172 (Ind) (xvii) Amandeep Singh Bhatia Vis. ACIT - 29 IT] ] (Ind) (xviii)Sanjay Agarwal Vis. DCIT -169 TT] 2821291 (Hyd) (xix) Himanshu B Kanakiya - 46ITR (Trib) 756 (Mum) (xx) Anant Steel Pvt Ltd t//s. ACIT - 28 IT] 47 (Ind) (xxi) DeIT Vis. Kalani Brothers (Indore) Pvt Ltd - (2016) 27 ITJ 286 (Ind-Trib) (xxii) Chandrabhan lalchandani V/so ACIT

GURSUKH ENERGY INDIA PVT. LTD., RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD 3 (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: 238/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

172/-, since the loan being availed by the assessee was not entirely used for business purposes. In aggregate, total disallowances were for Rs. 1,08,57,197/-. 5. Aggrieved with the aforesaid additions/ disallowance in the assessment u/s 147 by the Ld. AO, assessee preferred an appeal before the Ld. CIT(A), however, during the appellate proceedings, there

JOINT COMMISSIONER OF INCOME-TAX-RANGE-1,, BILASPUR vs. SOUTH EASTERN COALFIELDS LIMITED,, BILASPUR

The appeals of the assessee are partly allowed for statistical purposes and the appeal of the Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury,Jm Sl.

147 and 148 of the Act before issuing notice under section 148 of the Act. 1(c) That on the facts and in tire circumstances of the case, the CIT(Appeals) erred in upholding tire action of the Assessing officer in making addition/ disallowances on the other issues which were not the subject matter for the initiation of reassessment proceedings

JOINT.COMMISSIONER OF INCOME TAX RANGE -I, BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

The appeals of the assessee are partly allowed for statistical purposes and the appeal of the Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury,Jm Sl.

147 and 148 of the Act before issuing notice under section 148 of the Act. 1(c) That on the facts and in tire circumstances of the case, the CIT(Appeals) erred in upholding tire action of the Assessing officer in making addition/ disallowances on the other issues which were not the subject matter for the initiation of reassessment proceedings

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPUR(CG) vs. SOUTH EASTERN COAL FIELDS LTD.,, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR,BILASPUR(CG) vs. THE DY. COMMISSIONER OF INCOME TAX,CIRCLE , 1(1)BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

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

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources

THE DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE 1(1)BILASPUR, BILASPUR(CG) vs. THE SOUTH EASTERN COAL FIELDS LTD., BILASPUR, BILASPUR(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 5, when it is received or deemed to be received by a person. All income for the purpose of charge of income-tax and computation of total income is required to be classified under distinct heads of income such as salaries, income from house property, profits and gains of business or profession, capital gains and income from other sources