SURENDRA KUMAR DAGA,RAIPUR vs. ITO, WARD - 36(2), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri N.K. Choudhryassessment Year: 2013-14

120(1), the A.O. at Kolkata was ousted and could not have issued notice under section 143(2) of the Act. It was thus contended that the issuance of notice under section 143(2) by the A.O. at Kolkata itself is illegal and thus based on such illegal notice the assessment could not have been set into motion

INCOME TAX OFFICER, WARD-1(4), RAIPUR vs. MESERS G P INFRAVENTURES, RAIPUR

The appeal of the department stands disposed off

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

120 and this section, the word "case", in relation to any person whose name is specified in any order or direction issued thereunder, means all proceedings under this Act in respect of any year which may be pending on the date of such order or direction or which may have been completed on or before such date, and includes

M/S. G.P. INFRAVENTURES ,RAIPUR vs. INCOME TAX OFFICER-1(4), RAIPUR

The appeal of the department stands disposed off

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.76/Rpr/2020) (Assessment Year: 2015-16) Income Tax Officer Ward-1(4), V M/S G.P. Infraventures, 1St Floor, Aayakar Bhavan, S Shree Tower, Shankar Nagar, Central Revenue Building, Raipur (C.G.) Civil Lines, Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) : (""यथ" / Respondent) (Ita No.94/Rpr/2020) (Assessment Year: 2015-16) M/S G.P. Infraventures, V Income Tax Officer-1(4), Shree Tower, Shankar Nagar, S Raipur Raipur (C.G.) Pan: Aanfg6074B (अपीलाथ" /Applicant) (""यथ" / Respondent) : िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agarwal, Ca राज"व क" ओर से /Revenue By : Smt. Ila M. Parmar, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 10.10.2023 घोषणा क" तार"ख / Date Of : 23.11.2023 7Pronouncement

120 and this section, the word "case", in relation to any person whose name is specified in any order or direction issued thereunder, means all proceedings under this Act in respect of any year which may be pending on the date of such order or direction or which may have been completed on or before such date, and includes

SHRI SHAKTIDHAM INFRAVENTURE PRIVATE LIMITED,BILASPUR vs. PR. COMMISSIONER OF INCOME TAX, , BILASPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri N. K. Choudhryआयकर अपील सं./I.T.A. No. 71/Rpr/2020) ("नधा"रण वष" / Assessment Year : 2015-16)

68, 300/- and as per balance sheet he has made investment of Rs. 14,29,800/- in this company only arid he has no other asset. TOTAL 6711010 From the records it is seen that AO has not made proper examination/enquiry with respect to the source of share application money whereas these amount were got transferred from the account

M/S LNS INDUSTRIES LTD.,,DURG(CG) vs. DY. COMMISSIONER OF INCOME TAX, 1(1), BHILAI, BHILAI

Bench: Shri N.K. Billaiya & Shri Ram Lal Negi)

section 68 of the Act is applicable from 01.04.2013 i.e. A.Y. 2013-14 and therefore not applicable to the subject assessment year as held by the Co-ordinate Bench of Mumbai in the case of Gagandeep Infrastructure Pvt. Ltd. in ITA 5784/Mum/2011 which was subsequently confirmed by the Hon’ble High Court of Bombay

SHRI VIJAY KUMAR PATEL,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME-TAX, RAIPUR-1, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 212/Rpr/2024 ("नधा"रण वष" Assessment Year: 2017-18)

68 of the Act, penalty was not initiated u/s 271(1)(c) of the Act, whereas the case is related to AY 2017-18, therefore, the penalty provisions of section 271AAC are applicable. Accordingly, the assessment order 7 Shri Vijay Kumar Patel, Raipur vs PCIT, Raipur-1 dated 26.03.2022, is erroneous in so far as it is prejudicial

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. M/S R.R.ENERGY LTD.,, RAIGARH(C.G)

In the result, cross objections filed by the assessee for assessment years 2006-07, 2007-08 and 2008-09 are allowed and cross objections filed for the assessment years 2009-10, 2010-11, 2011-12 and...

section 68 are uncalled for and hence, deleted. The appellant gets relief of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 23. 10. Ground Nos.3 to 5 in appeals of Revenue for the assessment years 2006-07 and 2007-08 and ground Nos.1 to 4 in appeals for assessment