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56 results for “transfer pricing”+ Section 18clear

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Key Topics

Section 143(3)61Addition to Income32Disallowance32Section 14A19Depreciation18Section 14815Section 133A15Section 80I12Section 15112

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

ITA 95/RPR/2025[2014-15]Status: DisposedITAT Raipur30 Jul 2025AY 2014-15

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)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 147Section 250Section 92BSection 92C

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

Showing 1–20 of 56 · Page 1 of 3

Section 6812
Section 801A9
Deduction9

D.C.I.T. 2(1), RAIPUR vs. M/S BAGADIYA BROS. PVT. LTD., RAIPUR

Appeal is dismissed

ITA 387/BIL/2014[2010-11]Status: DisposedITAT Raipur11 Oct 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 92C(2)Section 92C(3)

Transfer Pricing Study (TP Study) before the AO / TPO. The turnover of the assessee company was Rs. 996 crores and the trading results were accepted by the Assessing Officer. The assessee has international transaction with the Associate Enterprise (AE) for vessel freight (chartering) of Rs. 232,72,71,145; vessel freight (trading) of Rs. 10,66,94,209/-; export

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

ITA 359/BIL/2014[2010-11]Status: DisposedITAT Raipur18 Jan 2018AY 2010-11

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

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

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

ITA 358/BIL/2014[2009-10]Status: DisposedITAT Raipur18 Jan 2018AY 2009-10

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

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

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

ITA 360/BIL/2014[2011-12]Status: DisposedITAT Raipur18 Jan 2018AY 2011-12

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

For Appellant: NoneFor Respondent: Shri P.K.Mishra, CIT DR
Section 14ASection 801ASection 80ISection 8Q

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

ITA 201/RPR/2022[2012-13]Status: PendingITAT Raipur16 Oct 2023AY 2012-13

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

For Appellant: Shri Amit M. Jain, AdvFor Respondent: Dr. Simran Bhullar, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14ASection 80I

18. It is admitted case that the CPP of the Assessee qualifies for claiming deductions under this sub-section 80-IA (4) (iv) of the Act. 19. Sub-section (8) of section 80-IA (80-IA (8)) (See Appendix-1) of the Act provides that for the purposes of deduction under this section profits and gains of eligible business

DCIT,1(1), RAIPUR (CG) vs. SMT VIMLESH KUMAR SINGH, RAIPUR (CG)

In the result, appeal filed by Revenue is dismissed

ITA 21/BIL/2013[2006-07]Status: DisposedITAT Raipur15 Jan 2018AY 2006-07

Bench: : Shri N.S.Saini & Shri Pavan Kumar Gadale, Judical Member Dcit-1(1), Raipur Vs Late Shri Vijay Pal Singh, Through L/H Smt. Vimlesh Kumari Singh, Prop.M/S Manohar Engineering & M/S Sharda Engineering, Baikunth, District – Raipur Pan No. : Ahjps 0124 K (Appellant) .. Tsednepser Revenue By : Mrs. Shital Verma, Dr Assessee By : Shri K.P.Dewani, Ar Date Of Hearing : 10/01/2018 Date Of Pronouncement 15/01/2018 आदेश / O R D E R Per Shri N.S.Saini, Am: This Is An Appeal Filed By The Revenue Against The Order Of The Cit(A), Raipur, Dated 08.02.2013 For The Assessment Year 2006-2007. 2. The Revenue Has Raised The Following Grounds :- “1. Whether In Law & On Facts & Circumstances Of The Case, The Cit(A) Has Erred In Deleting The Addition Of Rs.1,98,28,636/- Made By The Ao By Treating Long Term Capital Gain As Income From Undisclosed Sources.” 3. Brief Facts Of The Case Are That The Ao Observed That The Shares On Sale Of Which Ltcg Of Rs.1.95,39,611/- Was Shown & Exemption U/S.10(38) Of The Act Was Claimed Were Held Barely For Little More Than One Year To Qualify The Same As Long Term Capital Asset. The Cost Of The Shares Was Rs.2,69,400/- & Sale Consideration Was Rs.1,98,28,636/-. He

For Appellant: Shri K.P.Dewani, ARFor Respondent: Mrs. Shital Verma, DR
Section 10(38)

18 to 20 times in the price of such scrips. He opined that the assessee has controverted his unaccounted income into white income through long term capital gain and in this process has paid the tax at 10% against the normal rate of tax. 12. On appeal, the CIT(A) deleted the addition by observing as under :- 4.4) I have

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

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

ITA 187/RPR/2025[2018-19]Status: DisposedITAT Raipur11 Feb 2026AY 2018-19

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’).

For Appellant: Shri S. R. Rao, AdvocateFor Respondent: Shri Ram Tiwari, CIT-DR
Section 142(1)Section 147Section 148Section 263

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

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

ITA 93/BIL/2014[2004-05]Status: DisposedITAT Raipur16 Apr 2018AY 2004-05

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

Section 143(3)

Section 11 and 11 B 'of SEBl Act, 1992, hereby direct that the proceedings against Nageshwar investment Ltd., Adinath Bio-labs Ltd., Globe Stocks & Securities Ltd., Goenka Business & Finance Ltd., and Coronet Industries Ltd., shad stand terminated and I vacate the ad- interim order dated November 30, 2005. 15. Though the suspension order in respect of the some brokers including

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

ITA 365/BIL/2014[2011-12]Status: DisposedITAT Raipur01 Oct 2018AY 2011-12

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).

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri P. K. Mishra, CIT(DR)
Section 143(2)Section 143(3)Section 14ASection 3Section 80Section 80I

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

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

ITA 32/BIL/2017[2012-13]Status: DisposedITAT Raipur31 Oct 2022AY 2012-13

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) ..

For Appellant: Shri R.B.Doshi, CAFor Respondent: Shri G.N.Singh, Sr. DR
Section 145(3)Section 68

price of raw black stone + Direct expenses to make it saleable). It is further submitted by the ld. AR that books of accounts cannot be rejected merely on the ground that day to day register were not maintained by the assessee. Quantitative details of raw materials, finished products and by products were not furnished in 3CD report, but during

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), BILASPUR vs. MESERS NARMADA DRINKS PRIVATE LIMITED, BILASPUR

In the result ground No. 2 & 3 of the appeal of the revenue stands rejected

ITA 89/RPR/2020[2015-16]Status: DisposedITAT Raipur08 Nov 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 89/Rpr/2020) (Assessment Year: 2015-16) Deputy Commissioner Of Income Tax, Vs M/S Narmada Drinks Private Limited Circle-1(1), Aayakar Bhawan, Sirgitti Industrial Area, Tifra, Bilaspur Mahima Complex, Bilaspur (C.G.) (C.G.) Pan: Aaacn5880C (अपीलाथ" /Applicant) (""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 : 21.09.2023 घोषणा क" तार"ख/Date Of Pronouncement : 08.11.2023

For Appellant: Shri R.B. Doshi, CAFor Respondent: Shri V.K. Singh, CIT-DR
Section 143(3)Section 14ASection 40Section 40ASection 40A(3)Section 92C

18,77,750. The case of the assessee was later selected for scrutiny through CASS for Limited scrutiny. Further, the case was referred u/s 92CA of the Act to Additional CIT(TPO), Ahmadabad upon noticing that the assessee, during the year under consideration, had total specified domestic transactions of Rs. 27.99 Crores. On 22.10.18 the order u/s 92CA

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

ITA 345/RPR/2023[2015-2016]Status: DisposedITAT Raipur29 Jan 2025AY 2015-2016

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

For Appellant: Shri R.B Doshi, CA
Section 143(2)Section 143(3)Section 250Section 54BSection 54DSection 56(2)(vii)

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

ITA 157/BIL/2014[2011-12]Status: DisposedITAT Raipur23 Oct 2018AY 2011-12

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

Section 165Section 4Section 44A

section 143(3) of the I. T. Act for the A.Y.2003-04. We find from records that the assessee had only acquired a part of the lands (including some development works) required for the said railway track and siding which were subsequently transferred to LIPL and income arising thereof was shown under the head “Profits & Gains of Business or Profession

DEPUTY COMMISSIONER OF INCOME TAX-(1), RAIPUR, RAIPUR vs. AJAY GOLECHAA, RAIPUR

In the result, appeal of the Revenue is dismissed

ITA 454/RPR/2025[2014-15]Status: DisposedITAT Raipur20 Nov 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.454/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: None (Petition filed)For Respondent: Shri Ram Tiwari, CIT-DR
Section 10(38)Section 143(3)Section 271(1)(c)

18,810/- against the returned income of Rs.5,81,210/- thereby making an addition of Rs.17,37,600 for the year under consideration. The issue of addition is on account of claim of exemption under section 10(38) of the Income tax Act, 1961 on long term capital income with regard to sale of shares. 4 DCIT-1(1), Raipur

SMT. SMT. NEETU SHARMA,RAIPUR (CG) vs. THE DY. COMMISSIONER OF INCOME TAX 1(1), RAIPUR (CG)

In the result, appeal of the assessee in ITA No

ITA 351/BIL/2016[2011-12]Status: DisposedITAT Raipur30 Mar 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 351/Rpr/2016 "नधा"रण वष" / Assessment Year : 2011-12 Smt. Neetu Sharma Prop. Of Venkatesh Accessories Shoppe, Jawaharlal Nehru Ward No. 37, Sindhi Bazar, Near M.G Road, Raipur (C.G.) Pan : Bbhps6525D .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No. 352/Rpr/2016 "नधा"रण वष" / Assessment Year : 2011-12 Smt. Asha Sharma Prop. Of Venkatesh Enterprises, Sindhi Bazar, Near M.G Road, Raipur (C.G.) Pan : Ajjps9096A .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri Sunil Kumar Agrawal &For Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 133ASection 143(2)Section 143(3)

Section 133A does not empower any Income-tax Officer to examine any person on oath, therefore, any admission made in a statement recorded during the course of survey proceedings cannot form a standalone basis for making any addition. Our aforesaid view is supported by the judgment of the Hon’ble Supreme Court in the case of CIT v. S. Khader

SMT SMT ASHA SHARMA,RAIPUR (CG) vs. THE DY. COMMISSIONER OF INCOME TAX 1(1), RAIPUR (CG)

In the result, appeal of the assessee in ITA No

ITA 352/BIL/2016[2011-12]Status: DisposedITAT Raipur30 Mar 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 351/Rpr/2016 "नधा"रण वष" / Assessment Year : 2011-12 Smt. Neetu Sharma Prop. Of Venkatesh Accessories Shoppe, Jawaharlal Nehru Ward No. 37, Sindhi Bazar, Near M.G Road, Raipur (C.G.) Pan : Bbhps6525D .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No. 352/Rpr/2016 "नधा"रण वष" / Assessment Year : 2011-12 Smt. Asha Sharma Prop. Of Venkatesh Enterprises, Sindhi Bazar, Near M.G Road, Raipur (C.G.) Pan : Ajjps9096A .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri Sunil Kumar Agrawal &For Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 133ASection 143(2)Section 143(3)

Section 133A does not empower any Income-tax Officer to examine any person on oath, therefore, any admission made in a statement recorded during the course of survey proceedings cannot form a standalone basis for making any addition. Our aforesaid view is supported by the judgment of the Hon’ble Supreme Court in the case of CIT v. S. Khader

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

ITA 174/RPR/2019[2012-13]Status: DisposedITAT Raipur02 Sept 2022AY 2012-13

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

For Appellant: S/shri S.R Rao & Rajesh KumarFor Respondent: Shri P.K. Mishra, CIT-DR
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 64Section 65Section 68

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

ITA 63/RPR/2019[2013-14]Status: DisposedITAT Raipur02 Sept 2022AY 2013-14

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

For Appellant: S/shri S.R Rao & Rajesh KumarFor Respondent: Shri P.K. Mishra, CIT-DR
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 64Section 65Section 68

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

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

ITA 212/BIL/2014[2011-12]Status: DisposedITAT Raipur16 Apr 2018AY 2011-12

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

For Appellant: Shri P.K. Mishra, D.RFor Respondent: Shri Rajesh Kumar Chabra,C.A
Section 10Section 11Section 12ASection 2(15)Section 38(2)

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