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

254(1) of Income –tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This group of five appeals, out of which four appeals by Goyal Energy & Steel Private Limited are directed against the order of learned Commissioner of Income Tax (Appeals), hereinafter called as “ld. M/s. Goyal Energy & Steel Pvt. Ltd.& another ITA Nos.240-243 & 246/RPR/2019 CIT(A)” Bilaspur, dated

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

254(1) of Income –tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This group of five appeals, out of which four appeals by Goyal Energy & Steel Private Limited are directed against the order of learned Commissioner of Income Tax (Appeals), hereinafter called as “ld. M/s. Goyal Energy & Steel Pvt. Ltd.& another ITA Nos.240-243 & 246/RPR/2019 CIT(A)” Bilaspur, dated

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

254(1) of Income –tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This group of five appeals, out of which four appeals by Goyal Energy & Steel Private Limited are directed against the order of learned Commissioner of Income Tax (Appeals), hereinafter called as “ld. M/s. Goyal Energy & Steel Pvt. Ltd.& another ITA Nos.240-243 & 246/RPR/2019 CIT(A)” Bilaspur, dated

ADARSH NURSING INSTITUTE PVT LTD., RAIPUR,RAIPUR vs. ITO-4(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.534/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Adarsh Nursing Institute Private Limited Behind Sejbahar, Housing Board Colony, Near Kushabhau Thakre Univeristy, Datrenga, Raipur (C.G.)-492 013 Pan: Aagca6544C

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law. Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against the Revenue and hold that the Tribunal

PRAKASH KUMAR KSHATRIYA,RAJNANDGAON vs. INCOME TAX OFFICER, WARD-1, RAJNANDGAON, RAJNANDGOAN

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.436/Rpr/2025 "नधा"रण वष" /Assessment Year : 2016-17 Prakash Kumar Kshatriya House No.9, Ward No.44, Kaurin Bhata, Shiv Colony, Rajnandgaon-491 441 (C.G.) Pan: Cdhpk3190B .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1, Rajnandgaon (C.G.) ……""यथ" / Respondent

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law 8 Prakash Kumar Kshatriya Vs. ITO, Ward-1, Rajnandgaon Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against

SANDEEP SINGH,JUNA LAKHANPUR vs. ITO AMBIKAPUR, AMBIKAPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.448/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Sandeep Singh Juna Lakhanpur, Lakhanpur, Surguja-497 116 (C.G.) Ambikapur Pan: Gesps5929Q .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ambikapur (C.G.) ……""यथ" / Respondent

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against the Revenue and hold that the Tribunal

PRADEEP KUMAR KHANDELWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER,-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.46/Rpr/2024 "नधा"रण वष" /Assessment Year : 2011-12 Pradeep Kumar Khandelwal 10/683, Sector Balaji Nagar, Shivnand Nagar, Wrs Colony, Raipur-492 008 (C.G.) Pan: Bjypk5882N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Raipur (C.G.) ……""यथ" / Respondent

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against the Revenue and hold that the Tribunal

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.

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against the Revenue and hold that the Tribunal

NISHA NANWANI, RAIPUR,RAIPUR vs. ITO, WARD 2(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.352/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Nisha Nanwani Shail Villa, Flat No.502, Block-C, Maruti Life Style, Kota-492 001 (C.G.) Pan: Atepn5440L .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Raipur (C.G.) ……""यथ" / Respondent

68 of the Act and the Tribunal was not competent to make the said addition under Section 69-A of the Act, the entire order of the Tribunal stand vitiated in law Accordingly, we answer the question of law, as framed above, in favour of the appellant-assessee and against the Revenue and hold that the Tribunal

ANSHUKA TANEJA,AASTHA APARTMENT, SHANKAR NAGAR, RAIPUR vs. INCOME TAX OFFICER, WARD 3(2), CENTRAL REVENUE BUILDING, CIVIL LINES, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No. 391/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Smt. Anshuka Taneja E-7, E-Block, Aastha Apartment, Shankar Nagar, Opposite Wallfort Orchid, Sector-2, Raipur (C.G.)-492 004 Pan: Adupt5936D .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(2), Raipur (C.G.) ……""यथ" / Respondent

68 of the Act which talks of unexplained cash credit itself goes to the root of the matter vitiates the assessment order as well as impugned order i.e. order of the Ld. CIT(Appeals)/NFAC. 6. In a recent decision of the Co-ordinate Bench of Delhi in the case of Sanjeev Kumar c/o M/s Raj Kumar & Associates

DURGAWATI PANDAY,BAIKUNTHPUR vs. INCOME TAX OFFICER WARD NO 01, AMBIKAPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.14/Rpr/2026 "नधा"रण वष" /Assessment Year : 2020-21 Durgawati Panday Ward No.9, Mahalpara, Baikunthpur, Koriya Chhattisgarh-497 335 Pan: Dsipp8404G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward 1, Ambikapur (C.G.) ……""यथ" / Respondent

68 of the Act to the facts of the assessee’s case. Section 69A of the Act on the other hand applies to unexplained money, bullion, jewelry or other valuable article for which the assessee has not furnished any explanation about the nature and source of such money, bullion, jewelry or other valuable article etc. This wrong application

PRIYESH SINGHANIA, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.462/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Priyesh Singhania 730/1, Radha Kunj, Opposite Vip Guest House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 Pan: Aoups7838A ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

68,946/-, the break-up of Items of Exempt income S. No. 5 Others has been tabulated below which includes Exempt income of Rs. 7,41,718/- in the issue. Further, the relevant extract of 154 Return and Original return has been reproduced below: Full Copies of Original return and 154 Return has also been attached as Annex

SIKHA AGRAWAL, RAIGARH,RAIGARH vs. INCOME TAX OFFICER, WARD-1, RAIGARH, RAIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.235/Rpr/2025 "नधा"रण वष" /Assessment Year : 2019-20 Shikha Agrawal A-9, Ashirbadpuram Colony, Near Dhimrapur Chowk, Raigarh (C.G.)-496 554 Pan: Cjwpa0265J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1, Raigarh (C.G) ……""यथ" / Respondent

254 (All) which decision was referred to and applied in the earlier decision of the Co- 6 Shikha Agrawal Vs. ITO, Ward-1, Raigarh ordinate Bench of Delhi (supra), the Hon’ble High Court of Allahabad held as follows: “In the present case, it is apparent that the subject matter of the dispute all through before the Tribunal in appeal

SAROJ, KOREA,KOREA vs. PR. COMMISSIONER OF INCOME TAX, RAIPUR - 1, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.379/Rpr/2025 "नधा"रण वष" / Assessment Year : 2018-19 Saroj W/O. Ashok Kumar Jaiswal Pondi Bachra, Korea-497 449 (C.G.) Pan: Etzps9075K

254 (All) which decision was referred to and applied in the earlier decision of the Co-ordinate Bench of Delhi (supra), the Hon’ble High Court of Allahabad held as follows: “In the present case, it is apparent that the subject matter of the dispute all through before the Tribunal in appeal was only with regard to the addition

MITESH SINGHANIA,RAIPUR vs. INCOME TAX OFFICER WARD 1(2) RAIPUR, CENTRAL REVENUE BUILDING, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.410/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Mitesh Singhania Singhania Bhawan, Subhas Road, Near Telghani Naka, Raipur (C.G.)-492 001 Pan: Avops1474P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G) ……""यथ" / Respondent

68,946/-, the break- up of Items of Exempt income S. No. 5 Others has been tabulated below which includes Exempt income of Rs. 7,41,718/- in the issue. Further, the relevant extract of 154 Return and Original return has been reproduced below: Full Copies of Original return and 154 Return has also been attached as Annex

DAYARAM AGRAWAL, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-3(1), RAIPUR, RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.258/Rpr/2025 "नधा"रण वष" /Assessment Year : 2009-10 Shri Dayaram Agrawal H-1, Shankar Nagar, Rajeev Nagar, Raipur-492 007 (C.G.) Pan: Acgpa8622C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-3(1), Raipur (C.G.) ……""यथ" / Respondent

254 (All) which decision was referred to and applied in the earlier decision of the Co-ordinate Bench of Delhi (supra), the Hon’ble High Court of Allahabad held as follows: 6 Shri Dayaram Agrawal Vs. ITO-3(1), Raipur (C.G.) “In the present case, it is apparent that the subject matter of the dispute all through before the Tribunal

RAGHVENDRA SINGH THAKUR, RAIPUR,RAIPUR vs. INCOME TAX OFFICER-4(1), RAIPUR, RAIPUR

The appeal is allowed

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.242/Rpr/2025 "नधा"रण वष" /Assessment Year: 2013-14 Raghvendra Singh Thakur, H.No.238, Sarona, Tatibandh, Raipur, 492001, Chhattisgarh Pan: Akbpt7616E .......अपीलाथ" / Appellant बनाम / V/S.

254 (All) which decision was referred to and applied in the earlier decision of the Co- ordinate Bench of Delhi (supra), the Hon’ble High Court of Allahabad held as follows: “In the present case, it is apparent that the subject matter of the dispute all through before the Tribunal in appeal was only with regard to the addition

JOINT COMMISSIONER OF INCOME TAX (OSD) CIRCLE-1(1), BILASPUR vs. M/S OMAX MINERALS PVT. LTD. GADUMARIA, RAIGARH

In the result appeal ITA No

68 of the Act. We, therefore, do not find any reason to interfere with the finding of id. CIT(A)." 5. CIT V/s P. Mohankala, (2007) 291ITR 278 SC "The expression "the assessee offers no explanation" means the assessee offers no proper, reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessee