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)

35,782/- is contravene to the provisions of Sec. 68 of the Act. 13. Based on aforesaid reasons to believe, Ld. AO completed assessment and have made various additions u/s 68, 69C and section 69 of the Act. 14. Being aggrieved, assessee preferred an appeal before the Ld. CIT(A), wherein Ld. CIT(A) has granted substantial relief

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)

35,782/- is contravene to the provisions of Sec. 68 of the Act. 13. Based on aforesaid reasons to believe, Ld. AO completed assessment and have made various additions u/s 68, 69C and section 69 of the Act. 14. Being aggrieved, assessee preferred an appeal before the Ld. CIT(A), wherein Ld. CIT(A) has granted substantial relief

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -I, RAIPUR vs. LORD BUDDHA EDUCATIONAL SOCIETY, RAIPUR

In the result, the appeals of the revenue ITA Nos

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita Nos.188 To 193/Rpr/2019 (ननधाारण वषा / Assessment Year :2012-2013 To 2017-2018) Acit, Central Circle-1, Raipur(Cg) Vs M/S Lord Buddha Educational Society, M/S Raipur Institute Of Medical Sciences (Rims), Gram Godhi, Bhansoj Road, Office Nh-6, Raipur (Cg) Pan No. :Aaaal 3913 E (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

35,83,79,872/- and WIP Building at Rs. 22,33,77,614/- which clearly shows that the investment shown by the appellant is more than that shown in loose paper found during the course of search. iii) The A.O. has not mentioned any reason in the assessment order or in the reference to the valuation, that

SHRI GUNJAN KUMAR BIHANI, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3 (4), RAIPUR, RAIPUR

In the result, the captioned appeal filed by the assessee is allowed in terms of the aforesaid observations

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.122/Rpr/2025 "नधा"रण वष" / Assessment Year : 2015-16 Shri Gunjan Kumar Bihani Ashoka Ratan, Khamhardih, Shankar Nagar, Raipur-492 009 (C.G) Pan: Ajupb5787C

68 highly arbitrarily, unjustifiable and uncalled for. 4. Without prejudice to ground no. 1 & 2, the Id. CIT(A),NFAC has erred in determining the peak credit without making the necessary adjustments. 31 Shri Gunjan Kumar Bihani Vs. ITO, Ward-3(4), Raipur 5. That, Appellant reserves the right to add, amend, alter or withdraw any ground/grounds of appeal

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

35, in such case, once the assessee has opted as “No” regarding receiving of any notices/communications from the department through email, therefore, the assessee cannot be held at any fault for the delay caused. Accordingly, 3 Prakash Kumar Kshatriya Vs. ITO, Ward-1, Rajnandgaon the said delay of 42 days is condoned. I take guidance from the judicial pronouncements

JOINT.COMMISSIONER OF INCOME TAX RANGE -I, BILASPUR(CG) vs. SOUTH EASTERN COALFIELDS LTD, BILASPUR(CG)

The appeals of the assessee are partly allowed for statistical purposes and the appeal of the Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury,Jm Sl.

ab initio void and liable to be struck down. 1(b) That on the facts and in the circumstances of the case, the CIT(Appeals) failed to appreciate that the Assessing has not satisfied the pre-conditions mentioned in section 147 and 148 of the Act before issuing notice under section 148 of the Act. 1(c) That

JOINT COMMISSIONER OF INCOME-TAX-RANGE-1,, BILASPUR vs. SOUTH EASTERN COALFIELDS LIMITED,, BILASPUR

The appeals of the assessee are partly allowed for statistical purposes and the appeal of the Revenue in ITA

Bench: Shri Anil Chaturvedi, Am & Shri Partha Sarathi Chaudhury,Jm Sl.

ab initio void and liable to be struck down. 1(b) That on the facts and in the circumstances of the case, the CIT(Appeals) failed to appreciate that the Assessing has not satisfied the pre-conditions mentioned in section 147 and 148 of the Act before issuing notice under section 148 of the Act. 1(c) That

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

ab initio, since there is no application of mind, much less than any satisfaction arrived at by the A.O as well as by the Ld. CIT(Appeals)/NFAC. That the Co-ordinate Bench of Delhi in the case of Sanjeev Kumar c/o M/s Raj Kumar & Associates vs. ITO Ward 2(3)(2), Bulandshahr, reported in 2023(10) TMI 1027-ITAT

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)

ab-initio. 6. That, assessee reserves the right to add, amend, alter or withdraw any ground/grounds of appeal at the time of hearing. 3 Shri Vijay Kumar Patel, Raipur vs PCIT, Raipur-1 3. Further, the assessee has raised an additional ground during the appellate proceedings before us, same is culled out as under: 4 Shri Vijay Kumar Patel, Raipur

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

ab-initio, therefore, the same could not have been revised u/s. 263 of the Act for the reason, i.e. (a) that the reassessment order was passed based on the notice issued u/s. 148 of the Act, dated 26.07.2022 which was barred by limitation; (b) that as per the post-amended Section 149(1)(b) of the Act, the issuance

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

ab-initio, therefore, the same could not have been revised u/s. 263 of the Act for the reason, i.e. (a) that the reassessment order was passed based on the notice issued u/s. 148 of the Act, dated 26.07.2022 which was barred by limitation; (b) that as per the post-amended Section 149(1)(b) of the Act, the issuance

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

ab-initio, therefore, the same could not have been revised u/s. 263 of the Act for the reason, i.e. (a) that the reassessment order was passed based on the notice issued u/s. 148 of the Act, dated 26.07.2022 which was barred by limitation; (b) that as per the post-amended Section 149(1)(b) of the Act, the issuance

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

ab-initio, therefore, the same could not have been revised u/s. 263 of the Act for the reason, i.e. (a) that the reassessment order was passed based on the notice issued u/s. 148 of the Act, dated 26.07.2022 which was barred by limitation; (b) that as per the post-amended Section 149(1)(b) of the Act, the issuance