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

33. Be that as it may, as observed by the lower authorities and rightly so, the case of the assessee company falls within the realm of post- amended Section 68

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

33. Be that as it may, as observed by the lower authorities and rightly so, the case of the assessee company falls within the realm of post- amended Section 68

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

33. Be that as it may, as observed by the lower authorities and rightly so, the case of the assessee company falls within the realm of post-amended Section 68

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)

68 cannot be invoked in the garb of Section 263 as fiscal statute is to be given a strict interpretation. 16) Further observation made by the appellate Tribunal that consequential direction towards genuineness of stamp paper of receipt of advance from GTPL etc., being relatable to receipt of loans in other assessment year are apparently far- fetched and have

INCOME TAX OFFICER, WARD 2(1), RAIPUR vs. MESERS ARYAN BUILDERS AND DEVELOPERS PRIVATE LIMITED, RAIPUR

In the result, both appeal of the revenue and cross objection of the assessee stand dismissed in terms of our observations

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

68 of the Act?" 4. "Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) has erred by giving a finding which is contrary to the ratio of the decision of Hon'ble Supreme Court in the case of M/s Rajmandir Estates Pvt Ltd vs. PCIT-III, Kolkata

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

33 of the assessment order. 4. In the said reply, the assessee besides the other contentions specifically stated that additions can be made in the assessment under section 153A, if any incriminating evidences are found during the course of search. No such incrementing evidences regarding share application and share capital found during the search action

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

33 of the assessment order. 4. In the said reply, the assessee besides the other contentions specifically stated that additions can be made in the assessment under section 153A, if any incriminating evidences are found during the course of search. No such incrementing evidences regarding share application and share capital found during the search action

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

33 of the assessment order. 4. In the said reply, the assessee besides the other contentions specifically stated that additions can be made in the assessment under section 153A, if any incriminating evidences are found during the course of search. No such incrementing evidences regarding share application and share capital found during the search action

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

33 of the assessment order. 4. In the said reply, the assessee besides the other contentions specifically stated that additions can be made in the assessment under section 153A, if any incriminating evidences are found during the course of search. No such incrementing evidences regarding share application and share capital found during the search action

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

33 of the assessment order. 4. In the said reply, the assessee besides the other contentions specifically stated that additions can be made in the assessment under section 153A, if any incriminating evidences are found during the course of search. No such incrementing evidences regarding share application and share capital found during the search action

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

In the result, the appeal of revenue is dismissed

68 of the IT Act. Thus we do not perceive any reason to interfere with the observation of the Ld CIT(A) qua the impugned 18 allegation of the revenue and thus upheld the order of the CIT and reject this ground of revenue. 20. Apropos, the second issue with respect to disallowance u/s 14A. 21. Ld DR had strongly

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1), RAIPUR (CG) vs. M/S VANDANA VIDYUT LIMITED,, RAIPUR (CG)

In the result, appeal of the revenue is allowed for statistical purposes in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.138/Rpr/2017 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Vandana Vidyut Limited Vandana Building, M.G Road, Jawahar Nagar, Raipur (C.G.) Pan : Aaacv7850L ……""यथ" / Respondent

68 of the Act, the respective investor companies were obligated to offer an explanation about the nature and source of the sum credited in the books of account of the assessee company in the form of share capital/premium. Considering the totality of the aforesaid facts involved in the case before us, we are of the considered view that the matter

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

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

33,980/-. The relevant facts are that the assessee company had received share application money from Directors of the company. The Directors of the company had paid share application money to the company and in this regard, one of the Director, Shri Ramesh Gandhi had deposited an amount of Rs.3,50,000/- in his bank account and similarly, another Director

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

In the result both the appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.244 & 245/Rpr/2019 (ननधाारण वषा / Assessment Year :2016-2017 & 2017-2018) M/S Goyal Energy & Steel Pvt. Ltd. Vs Acit, Central-2, Raipur Behind Happy Restaurant, Ring Road-2, Tatiband Chowk, Raipur-492009 Pan No. :Aaccg 2758 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

section 68 and making an addition of Rs.22,33,09,760/- on account of receipt of share capital and premium

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

In the result both the appeals of the assessee are allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.244 & 245/Rpr/2019 (ननधाारण वषा / Assessment Year :2016-2017 & 2017-2018) M/S Goyal Energy & Steel Pvt. Ltd. Vs Acit, Central-2, Raipur Behind Happy Restaurant, Ring Road-2, Tatiband Chowk, Raipur-492009 Pan No. :Aaccg 2758 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

section 68 and making an addition of Rs.22,33,09,760/- on account of receipt of share capital and premium

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)

Section 68 of the Act stood discharged by the Assessee. 25 DCIT vs Balajee Loha Pvt. Ltd., Raipur 7. For the foregoing reasons, we are of the view that the impugned order of the Tribunal has to be set aside, answering the question of law, framed and quoted above, in favour of the Assessee

SMT SMT DHEERAJ DEVI KOTHARI,RAJNANDGAON vs. THE INCOME TAX OFFICER-1, RAJNANDGAON

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

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 15/Rpr/2016 "नधा"रण वष" / Assessment Year : 2011-12 Smt. Dheeraj Devi Kothari, Near Prakash Medicos, Balgovind Chowk, Rajnandgaon (C.G) Pan : Aezpk9549K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Rajnandgaon (C.G.) ……""यथ" / Respondent

Section 68. That our aforesaid view is fortified by the judgment of the Hon'ble High Court of Bombay in the case of CIT Vs. Bhaichand'N. Gandhi (1983) 141 ITR 67 (Bombay) wherein the Hon'ble High Court has held as under: - "As the Tribunal has pointed out, it is fairly well settled that when moneys are deposited