KAMLESH KUKREJA, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(1), RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 379/Rpr/2024 (िनधा"रण वष" Assessment Year: 2015-16)

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks –is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

SMT. ANITA BANODHA ALIAS ANITA KATHGAR , ANITA AUTO, PONDI CHIRMIRI KOREA,KOREA vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAIPUR, RAIPUR

In the result, appeal of the assessee is dismissed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.230/Rpr/2025 "नधा"रण वष" / Assessment Year : 2018-19 Smt. Anita Banodha Alias Anita Kathgar Anita Auto, Pondi, West Chirmiri, Korea (C.G)-497 449 Pan: Afgpj1876C ........अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax, Raipur-1(C.G.) ……""यथ" / Respondent

148A(d) of the Act has been obtained by the A.O from the specified authority that also is in conformity with and satisfies compliance of the “1st proviso” to Section 148 of the Act as per the Finance Act, 2021, w.e.f. 01.04.2021. Hence, we hold that the A.O was absolutely correct and was having inherent valid jurisdiction to issue

SMT. PINKY JHAWAR, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-1(2), RAIPUR, RAIPUR

Appeal is allowed for statistical purposes and Ground No

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 552/Rpr/2024 ("नधा"रण वष" Assessment Year: 2018-19)

section 1448. And CIT(A), NFAC is erred in not quashing the order of leamed AO on this legal ground raised by Appellant before him. 2. That on the fact and circumstances of case of Appellant the order passed u/s 147 r.w.s. 144 r.w.s. 1448 of IT Act is bad in law as the ld. AO failed to follow

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks –is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR, RAIPUR vs. USHA DEVI SINGHANIA, RAIPUR

In the result, appeal of the revenue in ITA No

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

68. In addition to the above, the time granted to the petitioner to respond to the notice dated 30.05.2022 – the period of two weeks –is also required to be excluded by virtue of the third proviso to Section 149(1) of the Act. The petitioner had furnished its response to the notice under Section 148A

SATISH KUMAR AGRAWAL, BHILAI,DURG vs. INCOME TAX OFFICER, WARD-2(1), BHILAI, DURG

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.145/Rpr/2024 "नधा"रण वष" / Assessment Year : 2018-19 Satish Kumar Agrawal 3B, Heav Industrial Area, Hathkhoj, Bhilai, Dist. Durg-490 026 (C.G.) Pan: Adqpa1785K

68 of the Act. 3 Satish Kumar Agrawal Vs. ITO, Ward-2(1), Bhilai 5) In the facts and circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals), NFAC is not justified in confirming action of Ld. Assessing Officer making addition of Rs.1,02,081/- u/s.69C of the Act by treating commission paid for bogus

INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR vs. VIGHNESHWAR ISPAT PVT LTD, RAIPUR

In the result, appeal of the revenue is dismissed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.343/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Income Tax Officer-3(1), Raipur (C.G.)

Section 148A(d) of the Income tax Act, 1961 and the assessment order dated 24.03.2023 is hereby set aside.” 9 ITO-3(1), Raipur Vs. Vighneshwar Ispat Pvt. Ltd. 3. The Ld. Sr. DR on principle admitted the applicability of the said decision of the Hon’ble Supreme Court (supra) by the Ld. CIT(Appeals)/NFAC but supported

SAKET PRODUCTS AND ROLLING MILL PVT. LTD., SURGUJA,SURGUJA vs. INCOME TAX OFFICER, WARD-1, AMBIKAPUR, AMBIKAPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 840/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Saket Products & Rolling Mill Vs Income Tax Officer, Ward 1, Private Limited, Aykar Bhawan, Kharsia Road, Subhash Marg, Bhaiyathan Road, Ambikapur, C. G., 497001 Surajpur, Surguja (C.G.) 497229 Pan: Aajcs2709N (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri G. S. Agrawal, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 16/02/2026 Pronouncement

148A did not accompany the information, inter-alia, statement of one Ketan Bhai Jayantilal Gazzar, suggesting that the income chargeable tax has escaped assessment. The Assessment Order be annulled or addition of Rs. 38,00,000/- be deleted. 4. That under the facts and the law, the Ld. Commissioner of Income Tax (Appeals) erred in dismissing the Appeal though

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.)

68 of the Act. It is recorded that "There is no dispute that the shares of the two companies were purchased online, the payments have been made through banking channel, and the shares were dematerialized, and the sales have been routed from the demat account, and the consideration has been received through banking channels." The above-noted factors, including

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.)

68 of the Act. It is recorded that "There is no dispute that the shares of the two companies were purchased online, the payments have been made through banking channel, and the shares were dematerialized, and the sales have been routed from the demat account, and the consideration has been received through banking channels." The above-noted factors, including

RAJU JHANGHEL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 250 of the Income Tax Act, 1961 (‘Act’), respectively. 3. In ITA No. 445/RPR/2025, the appellant assessee has raised following grounds of appeal: - “1. Gr.No.1: On the facts and circumstances of the case and in law, order u/s 148A(d) dt. 22-07-2022 and reopening u/s 148 dt. 25-7-22 for AY 14-15 under

RAJU JHANGHEL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-1(2), RAIPUR, RAIPUR

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

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 445 & 446/Rpr/2025 (िनधा"रण वष" Assessment Years: 2014-15 & 2015-16) Raju Janghel, C/E Beside Trivenia Vs Income Tax Officer-1(2), Office Of Houshal Pan Thela, Gudhiyari, Ito-1(2), Cr Building, Civil Lines, Raipur, Chhattisgarh, 492001. Raipur, Chhattisgarh, 492001 Pan: Agrpj0572D (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sunil Kumar Agrawal, Ca राज" की ओर से / Revenue By : Shri Yogesh Kumar Sharma, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 03.02.2026 घोषणा की तारीख / Date Of : 05.02.2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

section 250 of the Income Tax Act, 1961 (‘Act’), respectively. 3. In ITA No. 445/RPR/2025, the appellant assessee has raised following grounds of appeal: - “1. Gr.No.1: On the facts and circumstances of the case and in law, order u/s 148A(d) dt. 22-07-2022 and reopening u/s 148 dt. 25-7-22 for AY 14-15 under

INCOME TAX OFFICER-4(1), RAIPUR, CIVIL LINES, RAIPUR vs. SMITA MUKESH KEDIA, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 451/Rpr/2025 (िनधा"रण वष" Assessment Year: 2019-20)

148A(b) issued on 20.03.2022 and the assessee was required to furnished her explanation to the queries raised therein, in response, assessee submitted that she engaged in trading of coal under her proprietorship concern M/s UCL Enterprises and had computed her taxable income as per provisions of Section 44AD of the Act at 6% of the total turnover

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

148A(b) of the Act, dated 26.05.2022, revealed that the case of the assessee was, inter alia, sought to be reopened, for the reason that the land revenue 51 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 record (manual record) issued by Village patwari, dated 03.09.2019 stated that no agricultural activities were

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

148A(b) of the Act, dated 26.05.2022, revealed that the case of the assessee was, inter alia, sought to be reopened, for the reason that the land revenue 51 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 record (manual record) issued by Village patwari, dated 03.09.2019 stated that no agricultural activities were

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

148A(b) of the Act, dated 26.05.2022, revealed that the case of the assessee was, inter alia, sought to be reopened, for the reason that the land revenue 51 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 record (manual record) issued by Village patwari, dated 03.09.2019 stated that no agricultural activities were

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

148A(b) of the Act, dated 26.05.2022, revealed that the case of the assessee was, inter alia, sought to be reopened, for the reason that the land revenue 51 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 record (manual record) issued by Village patwari, dated 03.09.2019 stated that no agricultural activities were

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

148A(b) of the Act, dated 26.05.2022, revealed that the case of the assessee was, inter alia, sought to be reopened, for the reason that the land revenue 51 Sanket Jhabak & Others Vs. Pr. CIT-1, Raipur ITA No.478 & 479/RPR/2024 ITA Nos. 233 to 237/RPR/2024 record (manual record) issued by Village patwari, dated 03.09.2019 stated that no agricultural activities were