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

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

PRICE OF BOARD 16. Section 80-IA of the Act is titled as ‘Deductions in respect of profits and gains from industrial undertakings or enterprises engaged in infrastructure development, etc’. The CPP of the Assessee has claimed deductions under this section. 17. Clause (iv) of sub-section (4) of 80-IA (80-IA (4) (iv)) (See Appendix

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

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

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

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

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

THE ASSISTANT COMMISSIONER OF INCOME-TAX-4(1),RAIPUR, RAIPUR (CG) vs. THE CHHATTISGARH STATE ELECTRICITY BOARD THROUGH, RAIPUR (CG)

In the result appeal of the revenue is partly allowed

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.18/Rpr/2017 ("नधा"रण वष" / Assessment Year :2009-2010) Acit-4(1), Raipur Vs Chhattisgarh State Electricity Board, Through Chhattisgarh State Power Holding Company Ltd., O/O. General Manager Finance, Ground Floor, Vidyut Seva Bhavan, Dangania, Raipur Pan No. : Aabcc 7876 Q (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Madhur Agrawal, Adv. & Shri Praveen Khandelwal, Ca राज"व क" ओर से /Revenue By : Shri P.K.Mishra, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 02/08/2022 घोषणा क" तार"ख/Date Of Pronouncement : 31/10/2022 आदेश / O R D E R Per Arun Khodpia, Am : This Is An Appeal Filed By The Assessee Against The Order Passed By The Cit(A)-2, Raipur, Dated 22.12.2016 For The Assessment Year 2009- 2010, On The Following Grounds :- 1. “Whether On Points Of Law & On Facts & Circumstances Of The Case, The Ld. Cit(A) Was Justified In Deleting The Disallowance Of Rs.54,75,392/- Incurred On Coal Shortage?” 2. “Whether On Points Of Law & On Facts & Circumstances Of The Case, The Ld. Cit(A) Was Justified In Deleting The Disallowance Of Rs.6,08,96,17,054/- Claimed U/S.80Ia(4)(Iv)(C) Of The I.T.Act, 1961?” 3. The Order Of Ld. Cit(A) Is Erroneous Both In Law & Facts. 4. Any Other Ground That May Be Adduced At The Time Of Hearing 2. The Ground-Wise Decisions Are As Under:-

Section-2, relate to transit loss of fuel (72.1) and loss on settlement of claims for fuel (72.2). In the schedule 26A also, particulars furnished regarding material stock shortage pending investigation report a figure of Rs. 99,23,761/-. Thus as per the accounting system prescribed for assessee under ESAAR, 1985, claim of Rs. 54,75,392/- is made

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

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

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

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

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) ..

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), RAIPUR, RAIPUR vs. S.P. BUILDCON PVT. LTD., RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 35 & 38/Rpr/2023) (Assessment Year: 2014-15 & 2016-17) Deputy Commissioner Of Income Tax, V S.P. Buildcon Private Limited Circle-1(1), S Ff-06, Shyam Plaza, Pandri Bus Stand, Aayakar Bhawan, Civil Lines, Raipur Raipur Pan: Aajcs0653H (अपीलाथ" /Applicant) . (""यथ" / Respondent) . िनधा"रती क" ओर से /Assessee By : Shri Amit M. Jain, Adv. राज"व क" ओर से /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 05-09-2023 घोषणा क" तार"ख/Date Of Pronouncement : 28-11-2023

21. Apropos, the next contention raised by the assessee that provisions of Sec. 40(ai)(a) cannot be invoked in absence of any expenditure, referring to the judgment in the case of ClT vs. Dedicated Healthcare Services (TPA) India ltd. (supra), wherein Hon’ble Mumbai High Court has held that if there is no claim of expenses by the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAIPUR, RAIPUR vs. S.P. BUILDCON PVT. LTD., RAIPUR, RAIPUR

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No. 35 & 38/Rpr/2023) (Assessment Year: 2014-15 & 2016-17) Deputy Commissioner Of Income Tax, V S.P. Buildcon Private Limited Circle-1(1), S Ff-06, Shyam Plaza, Pandri Bus Stand, Aayakar Bhawan, Civil Lines, Raipur Raipur Pan: Aajcs0653H (अपीलाथ" /Applicant) . (""यथ" / Respondent) . िनधा"रती क" ओर से /Assessee By : Shri Amit M. Jain, Adv. राज"व क" ओर से /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 05-09-2023 घोषणा क" तार"ख/Date Of Pronouncement : 28-11-2023

21. Apropos, the next contention raised by the assessee that provisions of Sec. 40(ai)(a) cannot be invoked in absence of any expenditure, referring to the judgment in the case of ClT vs. Dedicated Healthcare Services (TPA) India ltd. (supra), wherein Hon’ble Mumbai High Court has held that if there is no claim of expenses by the assessee

DY. C.I.T.2(1), RAIPUR (CG) vs. SHRI SURESH ATLANI, RAIPUR (CG)

In the result, appeal filed by the revenue is dismissed

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2006-07 Dcit- 2(1), Abhishek Atlani, Raipur (Cg). Atlani Bunglow, Khamardih Road, Vs. Shankar Nagar, Raipur (Cg).

transfer of land. The agreement dated 01.04.2006 is not the agreement to sell the property in question, but it is an agreement having reference to some amount receivable from Suncity Project Pvt. Ltd. Neither the agreement nor the pen drive was found from the control and possession of the appellant and on the contrary, these were found from the brother

DY. C.I.T.2(1), RAIPUR (CG) vs. ABHISHEK ATLANI, RAIPUR (CG)

In the result, appeal filed by the revenue is dismissed

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2006-07 Dcit- 2(1), Abhishek Atlani, Raipur (Cg). Atlani Bunglow, Khamardih Road, Vs. Shankar Nagar, Raipur (Cg).

transfer of land. The agreement dated 01.04.2006 is not the agreement to sell the property in question, but it is an agreement having reference to some amount receivable from Suncity Project Pvt. Ltd. Neither the agreement nor the pen drive was found from the control and possession of the appellant and on the contrary, these were found from the brother

DY. C.I.T.2(1), RAIPUR (CG) vs. SHRI TARAL MODI, RAIPUR (CG)

In the result, appeal filed by the revenue is dismissed

Bench: Shri R. K. Panda & Ms. Suchitra Kambleassessment Year : 2006-07 Dcit- 2(1), Abhishek Atlani, Raipur (Cg). Atlani Bunglow, Khamardih Road, Vs. Shankar Nagar, Raipur (Cg).

transfer of land. The agreement dated 01.04.2006 is not the agreement to sell the property in question, but it is an agreement having reference to some amount receivable from Suncity Project Pvt. Ltd. Neither the agreement nor the pen drive was found from the control and possession of the appellant and on the contrary, these were found from the brother