DY. C.I.T. 1(2), RAIPUR (CG) vs. M/S HIRA FERRO ALLOYS LTD.,, RAIPUR

In the result, appeal filed for assessment year 2010-11 is dismissed

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

transferred is overstated in comparison to the market value, the A.O has power to re-compute the profit by substituting market value of such goods. In the explanation below section 801A(8), it is provided that, the expression "market value' for the purpose of the sub-section means the price that such goods or services would ordinarily fetch

DY. C.I.T. 1(2), RAIPUR (CG) vs. M/S HIRA FERRO ALLOYS LTD.,, RAIPUR

In the result, appeal filed for assessment year 2010-11 is dismissed

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

transferred is overstated in comparison to the market value, the A.O has power to re-compute the profit by substituting market value of such goods. In the explanation below section 801A(8), it is provided that, the expression "market value' for the purpose of the sub-section means the price that such goods or services would ordinarily fetch

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-(1), RAIPUR, RAIPUR vs. SHRI BAJRANG POWER AND ISPAT LTD., RAIPUR

The appeal of the revenue is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 201/Rpr/2022 "नधा"रण वष" / Assessment Years : 2012-13 The Assistant Commissioner Of Income Tax, Circle-1(1), Raipur. .......अपीलाथ" / Appellant बनाम / V/S. Shri Bajrang Power & Ispat Limited, 00, Vill. Borjhara, Urla Guma Road, Raipur-493221. Pan : Aaccb2944D ……""यथ" / Respondent

8) of Section 80IA of the Act. The A.O considering the rate of Rs. 2.93/- per unit, which was the average purchase rate of electricity by CGPGCL in Chhattisgarh, adopted the deemed sale value of electricity transferred to the captive division at Rs.2.93/- per unit as against Rs.3.17/- per unit as taken by the assessee company. Resultantly, the A.O restricted

DY C.I.T..1(1), RAIPUR (CG) vs. M/S RAIPUR DEVELOPMENT AUTHORITY, RAIPUR (CG)

Accordingly, we uphold the order of the First Appellate Authority. Appeal dismissed

Bench: Shri N.K. Billaiya & Shri Ram Lal Negi)

price at which any such land has been acquired from them. 16. The petitioners contended that the Corporation was a trading one. The reasons given were that the Corporation could sell property, namely, transfer land that the Corporation had borrowing powers ; and that the Corporation was entitled to moneys by way of rents and profits. Reliance was placed

NAYA RAIPUR DEVELOPMENT AUTHORITY,RAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), RAIPUR

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

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

price at which any such land has been acquired from them. 16. The petitioners contended that the Corporation was a trading one. The reasons given were that the Corporation could sell property, namely, transfer land that the Corporation had borrowing powers ; and that the Corporation was entitled to moneys by way of rents and profits. Reliance was placed

NAYA RAIPUR DEVELOPMENT AUTHORITY,RAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), RAIPUR

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

Bench: Shri Ravish Sood & Shri Rathod Kamlesh Jayantbhaiआयकर अपील सं. / Ita No. 174 & 63/Rpr/2019 "नधा"रण वष" / Assessment Year(S) : 2012-13 & 2013-14 Naya Raipur Development Authority Prayavas Bhawan, North Block, Sector 19, Naya Raipur Marg, Naya Raipur, Atal Nagar(C.G.) Pin-492 002. Pan : Aaalc0225H .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax (Exemption) Raipur (C.G.) ……""यथ" / Respondent Assessee By : S/Shri S.R Rao & Rajesh Kumar Chawda, Ar’S. Revenue By : Shri P.K. Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 09.06.2022 घोषणा क" तार"ख / Date Of Pronouncement : 02.09.2022

price at which any such land has been acquired from them. 16. The petitioners contended that the Corporation was a trading one. The reasons given were that the Corporation could sell property, namely, transfer land that the Corporation had borrowing powers ; and that the Corporation was entitled to moneys by way of rents and profits. Reliance was placed

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. C. G. ISPAT PRIVATE LIMITED, RAIPUR

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 95/Rpr/2025 (िनधा"रण वष" Assessment Year: 2014-15)

Section 92BA(i) of the Act, 1961 having been amended vide Finance Act, 2017 to exclude specified domestic transactions contained in Sec. 92BA(i) of the Act from the purview of Transfer Pricing Regulations, the findings of Ld. CIT(A) qua the said issue granting relief to the assessee are extracted here under, for the sake of completeness: 4 DCIT

ASSISTANT COMMISSIONER OF INCOME TAX-2(1), RAIPUR vs. M/S MAHENDRA SPONGE 7 POWER PVT LTD, RAIPUR

In the result, appeal of the Revenue is dismissed in terms of our aforesaid observations

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 197/Rpr/2017 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax-2(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Mahendra Sponge & Power Pvt. Ltd. Plot No.76 & 77, Industrial Growth Area, Siltara, Raipur (C.G.) Pan : Aadcm5765E ……""यथ" / Respondent

transferred to CSEB would not fall within the meaning of “market value” as contemplated in the “Explanation” to Section 80IA(8) of the Act, therefore, no adverse inferences on the said count were liable to be drawn in its hands. Apart from that, it was submitted by the assessee that the average 7 ACIT Vs. M/s. Mahendra Sponge & Power

DY. C.I.T.1(2), RAIPUR (CG) vs. M/S GODAWARI POWER & ISPAT LTD.,, RAIPUR (CG)

In the result, the appeal filed by the Revenue is partly allowed for

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2011-12 Dcit- 1(2), Godawari Power & Ispat Ltd., Raipur (Cg). Plot No.482/2, Industrial Growth Vs. Centre, Phase- 1, Siltara, Raipur (Cg).

transfers electricity to the Steel Division and other division, the captive power plant is doing so as a generator and distributor and not as a simple generator of electricity. Hence, it is clear that the market value for the transaction of sale of power from the captive power plant to the Steel Division shall be sale price of CSPDCL

CHANDHOK COLD STORAGE PVT. LTD., RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD-3(1), RAIPUR, RAIPUR

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

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 200/Rpr/2023 "नधा"रण वष" / Assessment Year : 2013-14 Chandhok Cold Storage Private Limited Ph No.100/28, Bilaspur Road, Ravigram S.O, Raipur-492 001 Pan : Aadcc8354P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

transfer at a general body meeting of the company; (iii) reserves and surplus, by whatever name called, even if the resulting figure is negative, other than those set apart towards depreciation; (iv) any amount representing provision for taxation, other than amount of tax paid as deduction or collection at source or as advance tax payment as reduced by the amount

THE DY. CIT-1(1),, RAIPUR (CG) vs. RAKESH SARAOGI & SONI (HUF),, RAIPUR (CG)

Bench: Shri N.K. Billaiya & Shri Ram Lal Negi)

8 C.O. Nos. 12 to 18/RPR/2014 . A.Y. 2004-05 read with Section 11 (4)(a), 11 (4)(b) and Section 11 (1) and 11B of SEBI Act issue further directions as under, pending investigation that: A) Taking into consideration of findings mentioned at paragraph 9.2 above, CSE's letter dated May 11, 2006 and May 12, 2006 and the suspension

ROSHAN LAL AGRAWAL,KORBA vs. INCOME TAX OFFICER , WARD-3, KORBA (C.G.)

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

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 240/Rpr/2023 "नधा"रण वष" / Assessment Year : 2011-12 Roshan Lal Agrawal Agrawal Rice Mill, Korba, Champa Road, Pahanda, Dist. Korba (C.G.)-495 677 Pan: Abapa0839N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-3, Korba (C.G.) ……""यथ" / Respondent

section 251 of the Act.” 9. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before me. 10. I have heard the ld. authorized representatives of both the parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been

JAIN ENTERPRISES, BHILAI,DURG vs. PCIT, RAIPUR-1, RAIPUR

In the result, appeal of the assessee is dismissed as above

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 187/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Jain Enterprises, Vs Pr. Commissioner Of Income Tax, 87-B, Light Industrial Area, Raipur-1, Central Revenue Building, Bhilai-490026, C.G. Civil Lines, Raipur, 492001, C.G. Pan: Aagfj3469G (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri S. R. Rao, Advocate राज" की ओर से / Revenue By : Shri Ram Tiwari, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against The Order Dated 24.03.2025 Of The Principal Commissioner Of Income Tax, Raipur-1 (‘Pcit’) Passed Under Section 263 Of The Income Tax Act, 1961 (‘Act’).

price for valuation of the closing stock (iii) non-appreciation of the transfer of quantitative details from VAT regime to GST regime and the hardship faced by the assessee during the course of transaction phase [VAT to GST]. 7. On the other hand, Shri Ram Tiwari, Ld. CIT-DR defended the impugned order by reiterating the details mentioned therein

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 145 of the Income Tax Act, Reliance is placed on the following decision:- s. Title Citation Authority No. 1. Atharva Rainbow Infratech ITA No. Hon’ble ITAT, Raipur vs. 177/RPR/2016 Bench DCIT-l(l), Raipur dated 01.04.2022 5.9 Moreover, there is nothing on record which establishes that the income had accrued or arisen to the assessee in the year

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 145 of the Income Tax Act, Reliance is placed on the following decision:- s. Title Citation Authority No. 1. Atharva Rainbow Infratech ITA No. Hon’ble ITAT, Raipur vs. 177/RPR/2016 Bench DCIT-l(l), Raipur dated 01.04.2022 5.9 Moreover, there is nothing on record which establishes that the income had accrued or arisen to the assessee in the year

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), RAIPUR vs. M/S R.N. NAVNIRMAN PRIVATE LIMITED, RAIPUR

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.143/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. R.N. Navnirman Pvt. Ltd. Vandana Building, Raipur (C.G.) Pan : Aadcr0896D ……""यथ" / Respondent Assessee By :Shri R.B Doshi, Ca Revenue By :Shri Sanjay Kumar, Sr. Dr

8. "Whether on points of law and on facts & circumstances of the case, the Ld. CIT(A) has erred in deleting the addition made u/s 14A, when clause (3) of the Section 14A of the Act clearly prescribes that provision of section 14A(2) shall also apply in relation to case where any assessee claims that no expenditure has been

RAHUL BAJPAI,IDGAH CHOWK vs. DCIT CIRCLE 1(1), SHRI RAM PLAZA

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

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.345/Rpr/2023 "नधा"रण वष" / Assessment Year : 2015-16 Rahul Bajpai Idgah Chowk, Bilaspur Chhattisgarh-495 001 Pan: Aexpb4410L .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

price) of the land in question. In the assessment proceedings, the AO observed that appellant bought land from Shri Somesh Sukla and the return of income of the appellant showed purchase cost of Rs.5,00,000/-, but stamp duty value of the land determined by the stamp duty authority was Rs.50,65,900/-. When asked to explain why the difference

DY.C.I.T. 1(2), RAIPUR (CG) vs. M/S RISHABH INFRASTRUCTURE PVT.LTD, RAIPUR

In the result, the appeal filed by the revenue is dismissed

Bench: Sh. R.K. Panda & Ms. Suchitra Kambleassessment Year: 2011-12

13. Aggrieved with such order of the CIT (A), the revenue is in appeal before the Tribunal by raising the following grounds :- 1. Whether in law and on facts & circumstances of the case, the learned CIT (A) has erred in deleting the addition of Rs.3,01,47,107/- made by the Assessing Officer on account of amount received from Lafarge