INCOME TAX OFFICER-1(1), BILASPUR vs. MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD. , BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

144B of the Act, alleging that the same was initiated based on search related information obtained from third party, attracting section 153C and not section 147, since section 153C Musaddilal Mansaram Infrasture Pvt. Ltd. vs. ITO, Ward-1(1), Bilaspur ITO, Ward-1(1), Bilaspur vs Musaddilal Mansaram Infrasture Pvt. Ltd. excludes the applicability of section

MUSADDILAL MANSARAM INFRASTRUCTURE PVT. LTD., BILASPUR,BILASPUR vs. INCOME TAX OFFICER, WARD-1(1), BILASPUR, BILASPUR

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

144B of the Act, alleging that the same was initiated based on search related information obtained from third party, attracting section 153C and not section 147, since section 153C Musaddilal Mansaram Infrasture Pvt. Ltd. vs. ITO, Ward-1(1), Bilaspur ITO, Ward-1(1), Bilaspur vs Musaddilal Mansaram Infrasture Pvt. Ltd. excludes the applicability of section

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, 69, 69A, 69B, 69C and 69D for any previous year, the assessee shall pay by way of penalty, in addition to tax payable under section 115BBE, a sum computed at a rate of 10% of the tax payable under clause (i) of sub section (1) of section 115BBE. In other words, penalty u/s 271AAC is applicable

ARUNA TIWARI,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 90/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Smt. Aruna Tiwari 762, Sundar Nagar, Raipur (C.G.)-492 001 Pan: Adbpt4977B .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax-1, Raipur (C.G.) ……""यथ" / Respondent

68,160/- on 31.03.2015. But on perusal of the bank statement kept on record i.e. SBI and Jila Sahkari Bank Ltd. no such transaction are being reflected in these accounts. On perusal of balance sheet, it is found that the assessee has maintained four accounts during the year. But the statement of bank account maintained at SBI (KCC) and Vijaya

TIKAMCHAND SAHU,AINTHAPALI vs. INCOME TAX OFFICER, MAHASAMUND, MAHASAMUND

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.494/Rpr/2025 िनधा"रण वष" /Assessment Year: 2022-23 Tikamchand Sahu, Ainthapali Imfl Off Shop, Sambalpur, Odisha, 768004 Pan: Hejps3794R .......अपीलाथ" / Appellant बनाम / V/S.

144B of the 1.T. Act. is arbitrary, unlawful and unjustified. As the assessee has furnished all the books of accounts in response to the notices and the assessee had also furnished all the required information and documents as per requirement to prove the genuineness of the transactions of unsecured loan. The AO was not justified and had made error

MADHU GOYAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-2(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.496/Rpr/2024 "नधा"रण वष" /Assessment Year : 2014-15 Smt. Madhu Goyal D-36, Wallfort City, Bhatagaon, Raipur-492 001 (C.G) Pan: Aeypg1038E .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-4(1), Raipur (C.G.) ……""यथ" / Respondent

section 68 of IT Act on account of long term capital gain derived from sale of listed equity shares without appreciating that the same script i.e. shares of M/s.Tilak Ventures Pvt. Ltd. are held to be genuine share by various court and also there is no allegation for appellants involvement in price rigging. Thus the addition made

VARDAAN INFRASTRUCTURES PRIVATE LIMITED,RAIPUR vs. INCOME TAX OFFICER, WARD 4(1), RAIPUR, RAIPUR

In the result, the appeal of assessee is allowed as above

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 834/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14) Vardaan Infrastructures Private Limited, Vs Income Tax Officer, Ward 4(1), C/S Shankar Marbles, Ring Road 1, Ayakar Bhawan, Civil Lines, Santoshi Nagar, Raipur, Chhattisgarh, Raipur, Chhattisgarh, 492001 Pan: Aadcv3823C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Praveen Khandelwal & Shri Praveen Goyal, Cas राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 09/02/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2013-14 Filed By The Assessee Is Directed Against The Order Dated 06.11.2025 Of Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

section 147 of the Act. 3. That on the facts and in the circumstances of the case and in law, the notice u/s 148 of the Act has been issued by the assessing officer on change of opinion, hence, illegal and bad in law. 4. That on the facts and in the circumstances of the case

KIRAN AGRAWAL, RAIPUR,RAIPUR vs. ITO, DHAMTARI, DHAMTARI

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: 655/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23)

144B of the Act is highly illegal, bad in law, suffers from legal infirmities, vitiated, unsustainable and hence liable to be quashed on the count of this ground alone. 3. On the facts and circumstances of the case as well as in law, the Ld. CIT(A) has grievously erred in affirming the action of the Ld. AO in making

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)

144B of the Act was erroneous in so far as prejudicial to the interest of revenue, therefore, the same needs to be revised under the provisions of section 263 of the Act. 3 Ardent Steels Private Limited vs. Pr. CIT, Raipur-1 3. With the aforesaid observations, Ld. PCIT issued a show-cause notice dated 27.09.2024 asking the assessee

SANJOG JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SAMPAT LAL JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SANJOG JHABAK L/H OF LATE GAUTAM CHAND JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAIPUR-1, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SMT. PUSHPA JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SMT. SUSHILA DEVI JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SMT. TILOTTAMA JHABAK, RAIPUR,RAIPUR vs. PCIT-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

SANKET JHABAK, RAIPUR,RAIPUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, all the appeals filed by the captioned assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpia

section 54B of the Act thereby tacitly accepting the claim of deduction put forward by the co-owners hence, it is most earnestly requested that the same treatment is deservedly required to be extended to the assessee individual and the returned income may please be assessed & accepted as such.” 54. We find that the A.O after considering the aforesaid

NAVRATAN JEWELLERS, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-4(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: 127/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

144B of the Act, dated 31.03.2022 passed by Income Tax Officer, National Faceless Assessment Centre, Delhi, (in short “Ld. AR”). 2 Navratan Jewellers Vs. ITO, Ward-4(1), Raipur 2. The grounds of appeal raised by the assessee are as under: 1. The Ld. CIT(A) has erred in setting aside the assessment order and remanding the matter

INCOME TAX OFFICER, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

Section 148 of the Income Tax Act, 1961 ( for short ‘the Act’). The said information reveals that the assessee had traded in the scrip of “Oasis Tradelink Ltd.” during the year. The said scrip was rigged by the entry provider namely Shri Naresh Manakchand Jain. The fact further illustrated by the A.O in the assessment order is that

INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR vs. RAHUL KATHURIA, RAIPUR

In the result, appeal of the Revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.151 & 152/Rpr/2025 "नधा"रण वष" / Assessment Years : 2018-19 & 2019-20 The Income Tax Officer/Income Tax Officer-3(1) Raipur (C.G.)

Section 148 of the Income Tax Act, 1961 ( for short ‘the Act’). The said information reveals that the assessee had traded in the scrip of “Oasis Tradelink Ltd.” during the year. The said scrip was rigged by the entry provider namely Shri Naresh Manakchand Jain. The fact further illustrated by the A.O in the assessment order is that