M/S PURVI FINVEST LIMITED,BILASPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1),, BILASPUR

In the result, appeal of the assessee company being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

68 of the Act. Elaborating on his aforesaid view, the A.O. relied on the judgment of the Hon'ble Supreme Court in the Case of A Govindarajulu Mudaliar, 34 ITR 807 (S.C.), and observed that if on verification of the documents, the A.O. was 10 M/s. Purvi Finvest Limited Vs. DCIT, Circle-1(1) unable to contact the share applicants

EAST WEST FINVEST INDIA LIMITED,BILASPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1), BILASPR

In the result, appeal of the assessee company being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

68 of the Act. Elaborating on his aforesaid view, the A.O. relied on the judgment of the Hon'ble Supreme Court in the Case of A Govindarajulu Mudaliar, 34 ITR 807 (S.C.), and observed that if on verification of the documents, the A.O. was 10 M/s. East West Finvest India Limited Vs.DCIT, Circle-1(1), Bilaspur unable to contact

M/S TRIMURTHY FINVEST LIMITED,BILASPUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), BILASPUR

In the result, appeal of the assesse company being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

10." As per the "1st Proviso" to Section 68 of the Act an additional obligation was fastened upon the assessee company to substantiate the authenticity of its claim of having received genuine share application money, and the respective investors were required to offer an explanation as regards the nature and source of the sum so credited against their name

ARDENT STEELS PVT. LTD., RAIPUR,RAIPUR vs. PR. COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 337/Rpr/2025 (िनधा"रण वष"Assessment Year: 2020-21)

10. Reverting to the specific provisions of Section 263 of the Act what has to be seen is that a satisfaction that an order passed by the Authority under the Act is erroneous and prejudicial to the interest of the Revenue is the basic pre- condition for exercise of jurisdiction under Section 263 of the Act. Both

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 1(1), RAIPUR vs. MESERS VANDANA ISPAT LIMITED, RAIPUR

In the result, the appeal of revenue is dismissed

section 68 of the Act. The order of the Ld CIT(A) shall be set aside being against the ratio of the settled law. The factual position of the case was not appreciated correctly by the Ld CIT(A), thus the decision rendered was perverse and deserves to be quashed. 7. Ld AR on this ground has submitted that

AGRAWAL INFRABUILD PRIVATE LIMITED ,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, RAIPUR

In the result, both appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.10 & 11/Rpr/2020 (ननधाारण वषा / Assessment Year :2013-2014 & 2014-2015) Agrawal Infrabuild Private Limited, Vs Acit, Central Circle-Ii, Raipur 1St Floor, V.R.Plaza, Bilaspur Pan No. :Aafca 6636 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

10% in all the years reopened/assesed u/s 153A and has shown an income higher than the estimate of 8% as approved by Settlement Commission, Kolkata duly accepted by the revenue department, on same line of business in the assessee’s own case for AY 2004-05 to 2010-11. Accordingly, assessee has already shown a higher income

AGRAWAL INFRABUILD PRIVATE LIMITED ,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-II, RAIPUR

In the result, both appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.10 & 11/Rpr/2020 (ननधाारण वषा / Assessment Year :2013-2014 & 2014-2015) Agrawal Infrabuild Private Limited, Vs Acit, Central Circle-Ii, Raipur 1St Floor, V.R.Plaza, Bilaspur Pan No. :Aafca 6636 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

10% in all the years reopened/assesed u/s 153A and has shown an income higher than the estimate of 8% as approved by Settlement Commission, Kolkata duly accepted by the revenue department, on same line of business in the assessee’s own case for AY 2004-05 to 2010-11. Accordingly, assessee has already shown a higher income

MESERS GOYAL ENERGY & STEEL PRIVATE LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR

In the result, all the appeals filed by the assessee vide ITA No

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singh

10. Now adverting to the adjudication of additional grounds of appeal and the Ground No. 3 of main grounds of appeal. The additional grounds of appeal relates to validity of approval under section 153D and Ground No. 3 of main grounds of appeal relates to validity of the additions under section 68 in absence of incriminating evidence found

MESERS GOYAL ENERGY & STEEL PRIVATE LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR

In the result, all the appeals filed by the assessee vide ITA No

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singh

10. Now adverting to the adjudication of additional grounds of appeal and the Ground No. 3 of main grounds of appeal. The additional grounds of appeal relates to validity of approval under section 153D and Ground No. 3 of main grounds of appeal relates to validity of the additions under section 68 in absence of incriminating evidence found

MESERS GOYAL INFRAVENTURES PRIVATE LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR

In the result, all the appeals filed by the assessee vide ITA No

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singh

10. Now adverting to the adjudication of additional grounds of appeal and the Ground No. 3 of main grounds of appeal. The additional grounds of appeal relates to validity of approval under section 153D and Ground No. 3 of main grounds of appeal relates to validity of the additions under section 68 in absence of incriminating evidence found

MESERS GOYAL ENERGY & STEEL PRIVATE LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR

In the result, all the appeals filed by the assessee vide ITA No

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singh

10. Now adverting to the adjudication of additional grounds of appeal and the Ground No. 3 of main grounds of appeal. The additional grounds of appeal relates to validity of approval under section 153D and Ground No. 3 of main grounds of appeal relates to validity of the additions under section 68 in absence of incriminating evidence found

MESERS GOYAL ENERGY & STEEL PRIVATE LIMITED,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAIPUR

In the result, all the appeals filed by the assessee vide ITA No

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singh

10. Now adverting to the adjudication of additional grounds of appeal and the Ground No. 3 of main grounds of appeal. The additional grounds of appeal relates to validity of approval under section 153D and Ground No. 3 of main grounds of appeal relates to validity of the additions under section 68 in absence of incriminating evidence found

SEEMA DEVI AGRAWAL,RAIGARH, CHHATTISGARH vs. INCOME TAX OFFICER, BILASPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.250/Rpr/2025 "नधा"रण वष" /Assessment Year : 2015-16 Smt. Seema Devi Agrawal C/O. Sunil Kumar Agrawal Sewa Kund Road, Raigarh-496 001 (C.G.) Pan: Affpa4990K .......अपीलाथ" / Appellant बनाम / V/S.

34 (SC). The facts and circumstances of the said referred judgment are substantially different 6 Seema Devi Agrawal Vs. DCIT, Circle-1(1), Bilaspur from facts in assessee’s case hence is misplaced by the revenue and further, it is observed that the Quasi-Judicial authority is duty bound to apply provisions of the Act in its strictest sense

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR vs. M/S TRIPCO SERVICES PVT. LTD., , RAIPUR

In the result, the appeal of the revenue is partly allowed in terms of our observations above

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.110/Rpr/2020 "नधा"रण वष" / Assessment Year : 2015-16

Section 68 of the Act are constrained to sustain the addition to the said extent. (F). NCR Buildmart Pvt. Ltd. Sr. No Name of the Amount No. of share Face value Premium @ shareholder received ( Rs.) allotted @10/- per 100/- per company share share (in Rs.) 1. M/s. NCR 25,00,000 200000 Nil Nil Buildmart Pvt. Ltd. (i). Although

MESERS DHARIWAL BROTHERS,RAIPUR vs. INCOME TAX OFFICER, WARD 3(1), RAIPUR

In the result, the appeal of the assessee is partly allowed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. No.186/Rpr/2018 (िनधा"रण वष" / Assessment Year : 2013-14) बनाम/ M/S. Dhariwal Brothers, Income Tax Officer- C/O. Raymond Retail Shop, Ward (3)(1), Raipur Vs. Jeewan Bima Marg, Pandri, Raipur (C.G.) "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadfd 6404 E (अपीलाथ" /Appellant) (""थ" / Respondent) ..

68 of the Act. In this view of the matter, we set aside the order of the CIT(A) on this point and direct the Assessing Officer to delete the addition on this score. 3. Consequently, Ground No.1 of the appeal of the assessee is allowed. 4. Ground No.2 concerns ad-hoc disallowance out of vehicle, travelling and telephone expenses

INCOME TAX OFFICER (EXEMPTION)-1, RAIPUR vs. SHRI CHAITANY MAHAPRABHU SHIKSHAN SANSTHAN, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 235/Rpr/2019 "नधा"रण वष" / Assessment Year : 2014-15 The Income Tax Officer, (Exemption)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Chaitany Mahaprabhu Shikshan Sansthan 2, Jindal Niwas, Ramsagarpara, Raipur(C.G.)-492 001 Pan : Aaits4845F ……""यथ" / Respondent Assessee By : Shri Sunil Kumar Agrawal & Smt. Laxmi Sharma, Cas Revenue By : Shri Sanjay Kumar, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 28.07.2022 घोषणा क" तार"ख / Date Of Pronouncement : 09.09.2022

Section 115BBC(3) of the Act. The aforesaid order of the ITAT, Delhi had thereafter been approved by the Hon’ble High Court of Delhi in the case of DIT(E), Delhi Vs. Hans Raj Samarak Society (2013) 35 Taxman 642 (Delhi).” We, thus, in terms of our aforesaid observations concur with the view taken

M/S. SUMIT GLOBAL PVT. LTD.,RAIGARH vs. INCOME TAX OFFICER - 1, RAIGARH

In the result, the appeal of the assessee is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.70/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 M/S. Sumit Global Pvt. Ltd. C/O Kanha Electricals & Electronics, Nanhu Nagar, Vijay Nagar, P.O. Kirodimalnagar, Raigargh (C.G.) Pan : Aaocs8271J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Raigarh (C.G.)

section 68 of the Income Tax Act, 1961. (iii) Whether the assessee has received share application of Rs. 2,26,41,500/- in assessment year prior to assessment year 2014-15 or not is a matter of verification. Accordingly, the AO is directed to verify the correctness of the figures given in para (i) above. In case

DEPUTY COMMISSIONER O F INCOME TAX, RAIPUR vs. BALAJEE LOHA PVT. LTD., RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 356/Rpr/2024 (िनधा"रण वष" Assessment Year: 2014-15)

10 DCIT vs Balajee Loha Pvt. Ltd., Raipur lnfotech Pvt. Ltd. and has added this amount as unexplained cash credit u/s 68 of the I. T. Act. 4.2.2 In reply, the appellant has stated that it had discharged its onus u/s 68 with respect to the identity, credit worthiness of the share-applicant company and the genuineness of the transaction