DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX( CENTRAL)-2, RAIPUR vs. MESERS SHREE JAGDAMBA CONSTRUCTION COMPANY, RAIPUR

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 37 To 42/Rpr/2020 ("नधा"रण वष" / Assessment Years : 2009-10 To 2014-15)

68 of the Income Tax Act, 1961 on account of unexplained loan received from M/s Zigma DealCom Pvt. Ltd. 2. Without prejudice to the above, on the facts and in the circumstances of the case the ld.CIT(A) erred in not appreciating the alternative basis of the addition of Rs.1,64,75,000/- which also attracts the provisions of section

PRAKASH GODHWANI,RAIPUR vs. INCOME TAX OFFICER, WARD 1(2), RAIPUR

In the result, the appeal of assessee is allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.136/Rpr/2019 (ननधाारण वषा / Assessment Year :2015-2016) Prakash Godhwani, Vs Ito-1(2), Raipur Prop. M/S Prakash Agency, Near Girls High School, Neora(Cg) Pan No. : Aglpg 2669 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

64 of Yes, PN 66 of PB. PB. Rs. 9.43 lakh, loan Rs. 6 lakh Sulochana Yes, PN 86. Yes. PN 86, Capital Rs. Godhwani 17.68 lakh, loan Rs. 15 lakh. 3. All the four lenders appeared before AO and statements recorded: - Name of Remarks Reference of statement reproduced lender in assessment order Smt. Page no. 6, question

INCOME TAX OFFICER (EXEMPTION)-1, RAIPUR vs. SHRI CHAITANY MAHAPRABHU SHIKSHAN SANSTHAN, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 235/Rpr/2019 "नधा"रण वष" / Assessment Year : 2014-15 The Income Tax Officer, (Exemption)-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. Shri Chaitany Mahaprabhu Shikshan Sansthan 2, Jindal Niwas, Ramsagarpara, Raipur(C.G.)-492 001 Pan : Aaits4845F ……""यथ" / Respondent Assessee By : Shri Sunil Kumar Agrawal & Smt. Laxmi Sharma, Cas Revenue By : Shri Sanjay Kumar, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 28.07.2022 घोषणा क" तार"ख / Date Of Pronouncement : 09.09.2022

68 of the Act by the A.O. Accordingly, the CIT(A) on the basis of his aforesaid observations vacated the addition of Rs. 2,33,52,000/- that was made by the A.O under Sec.68 of the Act. 6. The revenue being aggrieved with the order of the CIT(A) has carried the matter in appeal before

SMT. SEEMA AGRAWAL,RAIGARH vs. INCOME TAX OFFICER , WARD -I, RAIGARH

In the result, the appeal of assessee is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.179/Rpr/2017 (नििाारण वर्ा / Assessment Year :2011-2012) Seema Agrawal, Vs Ito, Ward-1, Raigarh Sewa Kunj Road, Near Girls College, Raigarh (C.G.) Pan No. : Affpa 4990 K (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) ..

section 68 of the I.T. Act, 1961. The assessee has credited interest upto 31.03.2011 at Rs.64.726/-. Thus the total addition works out to Rs.1,05,64

INCOME TAX OFFICER, WARD-1(2), BHILAI vs. MESERS METEX ENGINEERS, BHILAI

In the result Ground No 8 of the revenue is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.238/Rpr/2019 (Assessment Year: 2015-2016) M/S Metex Engineers, Vs Ito, Ward-1(2), Bhilai Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G & आयकर अपील सं./Ita No.247/Rpr/2019 (Assessment Year: 2015-2016) Ito, Ward-1(2), Bhilai Vs M/S Metex Engineers, Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri R.B.Doshi, Ca राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 24/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 14/06/2023 आदेश / O R D E R Per Arun Khodpia, Am :

Section 68: 6. At the outset Ld AR of the assessee has preferred not to press Ground Number 1 of the appeal by submitting as under: Ground No.1 - of the assessee’s appeal is directed against addition of Rs.5,50,000/- is not pressed as the Learned AO has allowed relief as per direction of Learned CIT (A) while

MESERS METEX ENGINEERS,BHILAI vs. INCOME TAX OFFICER, WARD-1(2), BHILAI

In the result Ground No 8 of the revenue is dismissed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.238/Rpr/2019 (Assessment Year: 2015-2016) M/S Metex Engineers, Vs Ito, Ward-1(2), Bhilai Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G & आयकर अपील सं./Ita No.247/Rpr/2019 (Assessment Year: 2015-2016) Ito, Ward-1(2), Bhilai Vs M/S Metex Engineers, Shop No.10-11, Ganesh Complex, Shakti Vihar, Risali Bhilai, Durg Pan No. :Aawfm 8852 G (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri R.B.Doshi, Ca राज"व क" ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 24/04/2023 घोषणा क" तार"ख/Date Of Pronouncement : 14/06/2023 आदेश / O R D E R Per Arun Khodpia, Am :

Section 68: 6. At the outset Ld AR of the assessee has preferred not to press Ground Number 1 of the appeal by submitting as under: Ground No.1 - of the assessee’s appeal is directed against addition of Rs.5,50,000/- is not pressed as the Learned AO has allowed relief as per direction of Learned CIT (A) while

THE ASSISTANT COMMISSIONER OF INCOME-TAX-CENTRAL CIRCLE-2,RAIPUR, RAIPUR (CG) vs. M/S DEVI IRON & POWER PVT LTD., RAIPUR, RAIPUR (CG)

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 267 & 268/Rpr/2014 Co Nos. 30 & 31/Rpr/2015 "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 The Deputy Commissioner Of Income Tax, Central Circle, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. Mahamaya Tower, 3Rd & 4Th Floor, In Front Of Anupam Nagar, Near Varun Honda, G.E. Road, Raipur (C.G.) Pan : Aaeca3704G ……""यथ" / Respondent आयकर अपील सं. / Ita No.101/Rpr/2017 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax (Central)-2, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. B-08-09, Sector-C, Industrial Area, Urla, Sarora, Raipur (C.G.) Pan : Aabcd9753D ……""यथ" / Respondent Co Nos.30 & 31/Rpr/2015

Section 68 of the Act, i.e., prior to insertion of the “1st Proviso” vide the Finance Act, 2012 w.e.f. 01.04.2013, the assessee company for the year under consideration i.e. A.Y.2011-12 remained under no statutory obligation to put forth an explanation as regards the source of source of the share application money received by it during the said year

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. DEVI IRON & POWER PVT LIMITED, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 267 & 268/Rpr/2014 Co Nos. 30 & 31/Rpr/2015 "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 The Deputy Commissioner Of Income Tax, Central Circle, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. Mahamaya Tower, 3Rd & 4Th Floor, In Front Of Anupam Nagar, Near Varun Honda, G.E. Road, Raipur (C.G.) Pan : Aaeca3704G ……""यथ" / Respondent आयकर अपील सं. / Ita No.101/Rpr/2017 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax (Central)-2, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. B-08-09, Sector-C, Industrial Area, Urla, Sarora, Raipur (C.G.) Pan : Aabcd9753D ……""यथ" / Respondent Co Nos.30 & 31/Rpr/2015

Section 68 of the Act, i.e., prior to insertion of the “1st Proviso” vide the Finance Act, 2012 w.e.f. 01.04.2013, the assessee company for the year under consideration i.e. A.Y.2011-12 remained under no statutory obligation to put forth an explanation as regards the source of source of the share application money received by it during the said year

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. DEVI IRON & POWER LIMITED, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 267 & 268/Rpr/2014 Co Nos. 30 & 31/Rpr/2015 "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 The Deputy Commissioner Of Income Tax, Central Circle, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. Mahamaya Tower, 3Rd & 4Th Floor, In Front Of Anupam Nagar, Near Varun Honda, G.E. Road, Raipur (C.G.) Pan : Aaeca3704G ……""यथ" / Respondent आयकर अपील सं. / Ita No.101/Rpr/2017 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax (Central)-2, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Devi Iron & Power Pvt. Ltd. B-08-09, Sector-C, Industrial Area, Urla, Sarora, Raipur (C.G.) Pan : Aabcd9753D ……""यथ" / Respondent Co Nos.30 & 31/Rpr/2015

Section 68 of the Act, i.e., prior to insertion of the “1st Proviso” vide the Finance Act, 2012 w.e.f. 01.04.2013, the assessee company for the year under consideration i.e. A.Y.2011-12 remained under no statutory obligation to put forth an explanation as regards the source of source of the share application money received by it during the said year

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held

ASSISTANT COMMISSIONER OF INCOME TAX-1(1),, RAIPUR vs. SHRI. JAVED ALI PRADHAN,, RAIPUR

In the result, all appeals filed by the Revenue are dismissed

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member

68 TTJ (Nag.) 616 it was held that in scrutiny assessment 'completed in consequence of search, no addition should be made on account of undisclosed income on estimations, presumptions, imaginations and guess work and income estimated on the basis of probabilities, possibilities, guess work, surmises and conjectures, cannot be assessed as undisclosed income, as held