DAMANJEET SINGH OBEROI, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, the appeal filed by the assessee is allowed

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Damanjeet Singh Oberoi Dcit, Circle 1(1), Raipur C/O Oberoi Tour & Travels, Shop No.1, Wali Mohd. Vs. Building, Kk Road, Moudhapara, Raipur – 492001 Pan: Aaepo3096L (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026

unexplained money u/s 69A on the basis of ledger account found at third party premises (Babylon Gr.); AO has not brought any material evidence on record for the alleged cash receipts, and therefore, application of sec 115BBE is not sustainable in the eyes of law and is liable to be deleted." Gr.No.5 "The appellant craves leave, to add, urge

THE INCOME TAX OFFICER -1, RAIGARH, RAIGARH(CG) vs. SHRI SHRI PARMANAND GUPTA, RAIGARH, RAIGARH(CG)

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 82/Rpr/2017 Co. No. 02/Rpr/2022 "नधा"रण वष" / Assessment Year : 2008-09 The Income Tax Officer-1, Raigarh (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Parmanand Gupta, Alochan Agrawal, L/H. Of Late Shri Parmanand Gupta, Prop. M/S. Balaji Handloom, 19/48, Palace Road, Raigarh (C.G.) Pan : Afdpg4961L ……""यथ" / Respondent

unexplained cash credits u/s. 68 of the Act. Accordingly, the CIT(Appeals) holding a conviction that the cash deposits in the bank accounts represented the sale proceeds of the assessee which were accounted by him in his books of account, thus, vacated the addition of Rs.5,22,81,663/- made by the A.O under

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)

147 are illegal and invalid, therefore, the same are liable to be dropped. 4. The objections of the assessee are rejected by the Ld. AO stating that the notice u/s 148 dated 28.03.2021 was sent on the last known address of the assessee by speed post No. EC1888518641IN. Hence, it is established that the notice u/s 148 was properly issued

DCIT(CENTRAL)-1, RAIPUR, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

DCIT(CENTRAL)-1,RAIPUR, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

DCIT(CENTRAL)-1, RAIPUR vs. KALMESH KUMAR KESHARWANI, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

KAMLESH KUMAR KESHARWANI,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR

In the result, appeal filed by the assessee in ITA No

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.122, 123 & 124/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 Kamlesh Kumar Kesharwani 112, Janta Colony, Gudhiyari, Raipur (C.G.)-492 001 Pan: Aewpk6876Q .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita Nos.135, 136 & 138/Rpr/2024 "नधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2015-16 The Deputy Commissioner Of Income Tax-(Central)-1, Raipur (C.G.)

reassessment within the meaning of “Explanation-2(c)(i)” of Section 147 of the Act, and also the complete details of the income assessed vide order u/ss. 143(3)/144 of the Act, dated 31.03.2016 were provided in the “reasons to believe”, dated 05.02.2018, therefore, the aforesaid contention of the Ld. AR being devoid and bereft of any merit

INCOME TAX OFFICER, RAIPUR vs. SANJAY KUMAR PUNJABI, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.565/Rpr/2025 िनधा"रण वष" /Assessment Year: 2019-20 Income Tax Officer, Central Revenue Building, Civil Lines, Raipur, Chhattisgarh, 492001 .......अपीलाथ" / Appellant बनाम / V/S.

147 r.w.s. 144B of the Act had assessed the income of the assessee at Rs.12,11,043/- after making addition of Rs.3,00,000/- regarding disallowance of claim u/s 80GGC and 3 Income Tax Officer Vs. Sanjay Kumar Punjabi Rs.73,513/- as unexplained money u/s 69A r.w.s. 115BBE of the Act. Penalty proceedings were separately initiated against the assessee

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

SHRI SHRI TARUN PUGALIA JAIN,RAIPUR (CG) vs. THE INCOME TAX OFFICER,WARD-1(4), RAIPUR (CG)

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 272/Rpr/2016 "नधा"रण वष" / Assessment Year : 2009-10 Shri Tarun Pugalia Jain Shop No.9, Kamala Super Bazar, Telghani Naka, Station Road, Raipur (C.G). Pan : Aacch4665D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(4), Raipur. ……""यथ" / Respondent

unexplained investment as regards the purchases in question. It was submitted by the Ld. AR that the addition made by the Assessing Officer had no rationale nexus with the very basis on which the case of the assessee was reopened u/s.147 of the Act. It was further submitted by the ld. A.R that a perusal of the ‘reasons to believe

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

MUKESH KUMAR MITTAL, SURAJPUR,SURAJPUR vs. INCOME TAX OFFICER, WARD-1, AMBIKAPUR, AMBIKAPUR

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

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No.04/Rpr/2025 "नधा"रण वष" / Assessment Year : 2011-12 Mukesh Kumar Mittal Bhaiyathan Road, Post-Surajpur (C.G)-497 229 Pan: Amlpm8514A .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1, Ambikapur (C.G.) ……""यथ" / Respondent

reassessment order passed u/s.143(3)/147 dt. 19/11/2018 of the Income Tax Act, 1961, is illegal and bad in law, and therefore all consequential orders, i.e. order passed u/s. 263 by Ld. PCIT, order passed u/s. 147 r.w.s 263 dt. 18/03/2022 [which has been appealed against before Ld. CIT(A)], and appellate order u/s.250 dt. 31/01/2024 [which is now appealed

HARJINDAR SINGH BAL,DURG vs. INCOME TAX OFFICER, WARD-2(1), BHILAI

The appeal of the assessee is partly allowed in terms of the aforesaid observations

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 57/Rpr/2020 "नधा"रण वष" / Assessment Year : 2010-11 Shri Harjindar Singh Bal Ward- No.29, Hospital Colony, Durg (C.G.)-491 001 Pan : Adepb7178F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(1), Bhilai (C.G.). ……""यथ" / Respondent

reassessment u/s.147 of IT Act, 1961 for a.y. 10-11.” On a careful perusal of the aforesaid “reasons to believe”, I am unable to concur with the claim of the Ld. AR that the proceedings u/s.147 of the Act had been initiated on the basis of vague, uncertain and non- specific facts. Also, the claim of the Ld. AR that

DCIT-1(1), BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

money of the beneficiaries. Sometimes, the shares of the LTCG beneficiaries are purchased by the beneficiaries of LOSS who later sell their shares when the price falls and hence book bogus LOSS in their books. All these transactions are done on the Stock Exchange and where the sale of shares are done after a holding of one year they fall

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

money of the beneficiaries. Sometimes, the shares of the LTCG beneficiaries are purchased by the beneficiaries of LOSS who later sell their shares when the price falls and hence book bogus LOSS in their books. All these transactions are done on the Stock Exchange and where the sale of shares are done after a holding of one year they fall

DCIT-1(1), BHILAI, BHILAI vs. VIJAYA DESHLAHRA, INDORE

In the result, ITA No. 92/RPR/2025 & C

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpia

money of the beneficiaries. Sometimes, the shares of the LTCG beneficiaries are purchased by the beneficiaries of LOSS who later sell their shares when the price falls and hence book bogus LOSS in their books. All these transactions are done on the Stock Exchange and where the sale of shares are done after a holding of one year they fall

AJMAT QURAISHI, RAIPUR,RAIPUR vs. ITO-4(1), RAIPUR, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 439/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

unexplained money, being total credits in bank accounts; when the assessee has only earned commission about 0.15% to 0.20% of total credit entries of Rs.5,69,26,750 in such bank account; the addition is liable to be deleted. 2. On the facts and circumstances of the case and in law, the ld CIT(A) has erred in sustaining