ANAND FOODS,DHAMTARI vs. INCOME TAX OFFICER, WARD DHAMTARI, DHAMTARI

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 239/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18)

reassessment order u/s 147 by invoking powers under the proviso below to clause (a) of sub-section (1) of section 251 of the Income Tax Act, 1961. Resultantly, Ld. CIT(A) directed Ld. AO to make fresh assessment after providing sufficient opportunities of being heard, considering all material facts, written submission and documentary evidence submitted by the assessee during

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

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of section

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of section

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of section

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of section

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of section

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) ..

69A or section 69. Provided that nothing contained J this section shall apply in respect of on assessment mode on or before the 30th day of September 2004, and where such assessment has become final and conclusive on or before that date} except in cases where a reassessment is required to be made in accordance with the provisions of 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)

reassessment proceedings null and void in light of judicial precedents made by the Honorable Courts and Tribunal. Ground No. 6. That the learned Commissioner of Income Tax (Appeals) NFAC ought to have admitted additional grounds of appeal raised by the assessee since they pertain to pure questions of law and do not require fresh evidence. Ground No. 7. The appellant

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)

reassessment proceedings null and void in light of judicial precedents made by the Honorable Courts and Tribunal. Ground No. 6. That the learned Commissioner of Income Tax (Appeals) NFAC ought to have admitted additional grounds of appeal raised by the assessee since they pertain to pure questions of law and do not require fresh evidence. Ground No. 7. The appellant

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

LOKESHWAR KUMAR SAHU,DHAMTARI vs. INCOME TAX ASSESSING OFFICER, DHAMTARI

The appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.510/Rpr/2025 िनधा"रण वष" /Assessment Year: 2014-15 Lokeshwar Kumar Sahu, Shri Balaji Construction Co. Near Rest House Kathuriya Complex, Ratnabandha Road, Dhamtari, Chhattisgarh. Pan: Ctnps5629H .......अपीलाथ" / Appellant बनाम / V/S.

147 is illegal, ab initio void inasmuch as there was no ”reason to believe” that there was escapement of income. The initiation of reassessment and consequent reassessment order passed is illegal, unsustainable, ab initio void. 2. That the learned CIT(A) erred both in law and on facts in failing to appreciate that the reassessment proceedings were initiated

NIDHI JAIN,GALI NO., SBI COLONY, FAFADIH,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR (C.G.), CIVIL LINES, RAIPUR (C.G.)

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 659/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14)

reassessment proceedings u/s 147, however, during the entire proceedings when the assessee was issued with notices u/s 148, 144B, 142(1), letter, SCN u/s 144 and additional SCN, chooses not to comply accordingly, Ld. AO has completed the assessment on best judgment assessment u/s 144 of the Act after considering the information available on record. In conclusion, an addition

SUKHDEV SINGH JOSHI,JAGDALPUR, BASTAR vs. INCOME TAX OFFICER, WARD, JAGDALPUR, JAGDALPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 173 & 174/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

u/s 147 read with section 148 to 151 of the Income Tax Act, 1961 is illegal and without jurisdiction because all the requisite conditions for initiating the proceedings are not fulfilled. 3. In the facts and circumstances of the case and in law, the ld. Commissioner of Income-tax (Appeals), NFAC has erred in confirming initiation of re- assessment proceedings

SUKHDEV SINGH JOSHI ,JAGDALPUR, BASTAR vs. INCOME TAX OFFICER, WARD, JAGDALPUR, JAGDALPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 173 & 174/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

u/s 147 read with section 148 to 151 of the Income Tax Act, 1961 is illegal and without jurisdiction because all the requisite conditions for initiating the proceedings are not fulfilled. 3. In the facts and circumstances of the case and in law, the ld. Commissioner of Income-tax (Appeals), NFAC has erred in confirming initiation of re- assessment proceedings

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

SURENDRA KUMAR CHANDRAKAR,DHAMTARI vs. INCOME TAX OFFICER, WARD-DHAMTARI, DHAMTARI

Appeals stands allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 193/Rpr/2024 (िनधा"रण वष" Assessment Year: 2017-18)

147, reopening u/s148 would be invalid; liable to be quashed; relied on Well Trans Logistics India P Ltd (2024) (Del HC); Lakhmani Mewaldas ( I976) (SC); Meenakshi Overseas (P) Ltd (2017) (Del HC); Mohanlal ChampalaI Jain (2019) (Born HC); Shamshad Khan (2017) (Del HC); Mumtaz Haji Mohmad Memon (2018) (Guj)." Additional Gr.No.2: “On the facts and circumstances of the case

SOURABH AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.735/Rpr/2025 िनधा"रण वष" /Assessment Year: 2019-20 Sourabh Agrawal, Prop. Sawaria Traders, Shop No.217, Samta Colony, Raipur, Chhattisgarh. Pan: Appa0229M .......अपीलाथ" / Appellant बनाम / V/S.

147 r.w.s. 148A of the Act on the basis of information shared with the AO through ITBA as per the Risk Management Strategy formulated by the CBDT, according to which, the assessee had made cash payment of Rs.25,00,000/- to Shree Shyam Sales Corporation, but the source of the said cash payment was not explained. Notice u/s 148 r.w.s

RASHI STEEL AND POWER LIMITED,BILASPUR vs. ACIT, NEW DELHI

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./ Ita No. 73/Rpr/2021 (Assessment Year: 2012-13) M/S Rashi Steel & Power Ltd. Vs Acit Cf9, Rajeev Plaza, Bilaspur New Delhi Pan No. :Aaecr 6450 Q : Shri R.B.Doshi, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : Shri Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 01/06/2023 घोषणा क" तार"ख/Date Of Pronouncement : 08/06/2023

69A mandates addition only 3 in case the assessee is found to be owner of money, bullion etc. not recorded in the books of account. 12. That the Learned CIT(A) has erred both in law and facts of the case in confirming the addition of Rs.85,00,000/- in the hands of the appellant due to misinterpretation of section