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

75,000/- has been received from his mother in earlier years and from employer and compensation through court order. In this regard, the assessee has also submitted capital account of himself and his mother. The Ld. CIT(Appeals)/NFAC had failed to conduct any enquiry as mandated in Section 250(4) & (6) of the Act and had summarily dismissed

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

68 has been amended by Finance Act, 2012 inserting the sub-section 1 that source of source has to be proved in the cases of share application money ? 5. "Whether on the facts of the cases and in law, the CIT(A) is justified in replying on jurisdictional high court order in the case of ACIT Vs Venkateshwar (spat

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)

68 of the Act, it was open to the department to take recourse of section 131 or section 133(6) of the Act, if they were to further proceed, that not having done so, the First Appellate Authority was within its jurisdiction to conclude on facts and law, in favour of the assessee. 6.3 In the case

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

SUBRAMANIAM SWAMINATHAN IYER, BHILAI,DURG vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), BHILAI, DURG

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.71/Rpr/2023 "नधा"रण वष" / Assessment Year : 2012-13 Subramaniam Swaminathan Iyer 12-A/7, Nehru Nagar, Bhilai (C.G.)-490 020 Pan: Anwps2381P

68 of the Act, addition of Rs.68,62,394/- on account of other credits, addition of Rs.6,12,607/- on account of deemed sales tax, addition of Rs.55,06,957/- u/s 14A read with rule 8D of the I. T. Rules, 1962 and disallowance of Rs. 1,45,75,000/- on account of deemed dividend

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

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

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

section 68 of the Act? 4. Whether on the facts and circumstance of the case and on the points of the law Ld. CIT(A) was justified in deleting the addition of Rs. 2,25,00,000/- made by the AO relying upon the decision in cases which are distinguishable in facts from the case of the assessee

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)

75,92,450/- made under section 69 of the Act on account of the difference between the stamp duty value of the properties and the documented purchase price as per section 50C of the Act, by applying a 10% tolerance limit retrospectively, and further erred in holding that the correct provision applicable was section

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)

75,92,450/- made under section 69 of the Act on account of the difference between the stamp duty value of the properties and the documented purchase price as per section 50C of the Act, by applying a 10% tolerance limit retrospectively, and further erred in holding that the correct provision applicable was section

MESERS FASHION HOUSE,RAIPUR vs. INCOME TAX OFFICER- 4(3), RAIPUR

In the result, appeal of the assessee is allowed

Bench: Shri Partha Sarathi Chaudhury & Dr. Mitha Lal Meenaआयकर अपील सं. / Ita No. 217/Rpr/2018 धनधाारण वषा / Assessment Year : 2013-14 M/S. Fashion House, Malviya Road, Raipur (C.G.) Pin-492 001 Pan : Aacff3323M .......अपीलाथी / Appellant बनाम / V/S. The Income Tax Officer-4(3), Raipur (C.G.) ……प्रत्यथी / Respondent Assessee By : Shri R.B. Doshi Revenue By : Smt. Anubhaa T. Goel

68 was not complied with and he added the entire amount of Rs.58,50,000/- in the hands of the assessee. 5. The Ld. CIT(Appeals) as per details reasons and observations as appearing in his order was of the opinion that it is always the onus of the assessee to establish the identity , creditworthiness of the creditors and genuineness

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) ..

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.1,05,64,726/- u/s.68 of the I.T.Act, 1961. 7 7. The statement of Shri Sunil Kumar Agrawal, the key person, who was operating the bank account, made admission before the investigation wing. Thereafter Sunil Kumar Agrawal filed

SMT SMT. PRIYA SONI,RAIPUR (CG) vs. THE INCOME TAX OFFICER, WARD-4(5), RAIPUR (CG)

In the result, the appeal of the assessee is partly allowed in terms of our aforesaid observations

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.32/Rpr/2017 (ननधाारण वषा / Assessment Year : 2012-2013) Smt. Priya Soni, Vs Ito, Ward-4(5), Raipur C/O-M/S Shivani Jewellers Ramnarayan Soni, Lilli Chowk, Purani Basti, Raipur Pan No. : Awips 5478 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

75,000/- from Smt. Shanti Soni and in connection with the loan taken the assessee was required to furnish confirmations in order to prove the identity, creditworthiness and genuineness of the transactions. Since the assessee did not furnish the necessary details such as complete address, PAN of Smt. Shanti Soni, and Bank statements the AO concluded that the loans

D.C.I.T. CENTRAL CRICLE,, RAIPUR vs. MAHALAXMI TECHNOCASR LTD, RAIPUR

Bench: Shri Pradip Kumar Kedia & Shri Pawan Singhआयकर अपील सं./I.T.A. Nos. 256 To 259/Rpr/2014

75,00,000/- (A.Y. 2009-10), (3) Rs.5,45,00,000/- (A.Y.2010-11) & Rs.70,00,000/- (A.Y. 2011- 12) carried out by the AO under the provisions of Section 68