Income Tax Appellate Tribunal - Raipur
Vijay Kumar Gupta,Raipur vs Income Tax Officer.Ward 1(2), Raipur, ... on 11 May, 2026
आयकर अपील य अ धकरण यायपीठ "एक-सद य" मामला रायपरु म
IN THE INCOME TAX APPELLATE TRIBUNAL
RAIPUR BENCH "SMC", RAIPUR
ी पाथ सारथी चौधर , या यक सद य के सम
BEFORE SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER
आयकर अपील सं./ITA No.310/RPR/2026
नधारण वष /Assessment Year : 2013-14
Vijay Kumar Gupta
South Avenue, Choubey Colony,
Raipur-492 001 (C.G.)
PAN: AQUPG7344K
.......अपीलाथ / Appellant
बनाम / V/s.
The Income Tax Officer,
Ward-1(2), Raipur (C.G.)
...... यथ / Respondent
Assessee by : S/shri Praveen Khandelwal &
Praveen Goyal, CAs
Revenue by : Shri CH. Rajeswara Reddy, Sr. DR
सुनवाई क तार ख / Date of Hearing : 11.05.2026
घोषणा क तार ख / Date of Pronouncement : 11.05.2026
2
Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.)
ITA No.310/RPR/2026
आदे श / ORDER
PER PARTHA SARATHI CHAUDHURY, JM
The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 05.02.2026 for the assessment year 2013-14 as per the grounds of appeal on record.
2. In this case, JCIT, Range-2, Raipur had levied penalty of Rs.36,25,000/- u/s.271D of the Income Tax Act, 1961 (for short 'the Act') without initiating penalty in the assessment order itself. In other words, there is no satisfaction emanated from the assessment order for initiating penalty u/s.271D of the Act. That in absence of such satisfaction, the A.O had separately issued show-cause notice to the assessee and thereafter, had passed penalty order u/s.271D of the Act, dated 28.12.2017 imposing penalty.
3. It is the contention of the Ld. Counsel for the assessee that without recording satisfaction for initiation of the penalty in the assessment order, there cannot be any penalty levied on the assessee. It was submitted by the Ld. Counsel that in the assessment order, there has been no addition on the quantum, therefore, there was no initiation of penalty.
4. Per contra, the Ld. Sr. DR submitted that even if there was no initiation of penalty u/s.271D of the Act, however, it was within the power 3 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 of the A.O to issue show cause notice separately and pass penalty order u/s.271D of the Act. It was contended by the Ld. Sr. DR that even if there was no addition in the assessment order, therefore, there arose no opportunity for levy of penalty. However, subsequently if the A.O found that it is relevant to issue show cause notice and impose penalty, such process is valid.
5. Having heard the submissions of the parties herein, I find that the issue is no more "Res-integra". The penalty sustains only if there is addition in the quantum. In the assessment order, there is no demand and the returned income has been accepted by the A.O, therefore, there does not arise any cause for satisfaction to initiate any penalty since quantum has already been accepted. That without any satisfaction for initiation of penalty itself in the assessment order, the law does not provide any power to the A.O to separately issue show cause notice and pass penalty order. If this is allowed, it would be double jeopardy to the assessee where in the return filed, on one hand, the A.O accepts the returned income and does not initiate penalty since quantum is accepted, on the other hand, he issues separate show cause notice and passes penalty order against the assessee. This double jeopardy through double adjudication of the returned income is not permissible within the parameters of the Act. It is settled principle that initiation of penalty 4 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 depends on the quantum addition and in the assessment order after enquiries done by the A.O, if return is accepted and no addition is there on quantum, thus there does not arise in the assessment any occasion for order for satisfaction to initiate penalty.
6. The Hon'ble Supreme Court in the case of CIT, Panchkula Vs. Jai Laxmi Rice Mills Ambala City, (2025) 64 taxmann.com 75 (SC) on the aforesaid issue has held and observed as follows:
"3. After remand, the Assessing Officer passed fresh assessment order. In this assessment order, however, no satisfaction regarding initiation of penalty proceedings under Section 271E of the Act was recorded. It so happened that on the basis of the original assessment order dated 26.02.1996, show cause notice was given to the assessee and it resulted in passing the penalty order dated 23.09.1996. Thus, this penalty order was passed before the appeal of the assessee against the original assessment order was heard and allowed thereby setting aside the assessment order itself. It is in this backdrop, a question has arisen as to whether the penalty order, which was passed on the basis of original assessment order and when that assessment order had been set aside, could still survive.
4. The Tribunal as well as the High Court has held that it could not be so for the simple reason that when the original assessment order itself was set aside, the satisfaction recorded therein for the purpose of initiation of the penalty proceeding under Section 271E would also not survive. This according to us is the correct proposition of law stated by the High Court in the impugned order.
5. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act.5
Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied. These appeals are, accordingly, dismissed."
7. This Bench of the Tribunal after relying on the decision of the Hon'ble Apex Court in the case of CIT, Panchkula Vs. Jai Laxmi Rice Mills Ambala City (supra) in the case of Bhowmick Raj Singh Vs. Jt.
Commissioner of Income Tax (2025) 171 taxmann.com 575 (Raipur-
Trib) has held as follows:
"10. We 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 pressed into service by the Ld. AR to drive home his contentions.
11. Before proceeding any further, it would be relevant to cull out the provisions of Section 269SS of the Act, i.e., the mandate of law which contemplates that no loan/deposit in excess of a specified amount is to be received by an assessee otherwise than as per the prescribed modes, which reads as under:
"269SS. No person shall take or accept from any other person (herein referred to as the depositor), any loan or deposit or any specified sum, otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account 11[or through such other electronic mode as may be prescribed], if,--
(a) the amount of such loan or deposit or specified sum or the aggregate amount of such loan, deposit and specified sum; or
(b) on the date of taking or accepting such loan or deposit or specified sum, any loan or deposit or specified sum taken or accepted earlier by such person from the depositor is remaining unpaid (whether repayment has fallen due or not), the amount or the aggregate amount remaining unpaid; or 6 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026
(c) the amount or the aggregate amount referred to in clause
(a) together with the amount or the aggregate amount referred to in clause (b), is twenty thousand rupees or more:
Provided that the provisions of this section shall not apply to any loan or deposit or specified sum taken or accepted from, or any loan or deposit or specified sum taken or accepted by,--
(a) the Government;
(b) any banking company, post office savings bank or co-
operative bank;
(c) any corporation established by a Central, State or Provincial Act;
(d) any Government company as defined in clause (45) of section 2 of the Companies Act, 2013 (18 of 2013);
(e) such other institution, association or body or class of institutions, associations or bodies which the Central Government may, for reasons to be recorded in writing, notify in this behalf in the Official Gazette:
Provided further that the provisions of this section shall not apply to any loan or deposit or specified sum, where the person from whom the loan or deposit or specified sum is taken or accepted and the person by whom the loan or deposit or specified sum is taken or accepted, are both having agricultural income and neither of them has any income chargeable to tax under this Act.
Explanation.--For the purposes of this section,--
(i) "banking company" means a company to which the provisions of the Banking Regulation Act, 1949 (10 of 1949) applies and includes any bank or banking institution referred to in section 51 of that Act;
(ii) "co-operative bank" shall have the same meaning as assigned to it in Part V of the Banking Regulation Act, 1949 (10 of 1949) ;
(iii) "loan or deposit" means loan or deposit of money;
(iv) "specified sum" means any sum of money receivable, whether as advance or otherwise, in relation to transfer of an immovable property, whether or not the transfer takes place."7
Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 As the failure to comply with the provisions of Section 269SS of the Act results in saddling the assessee with penalty u/s. 271D of the Act; therefore, it would be relevant to cull out the same as under:
"271D. (1) If a person takes or accepts any loan or deposit or specified sum in contravention of the provisions of section 269SS, he shall be liable to pay, by way of penalty, a sum equal to the amount of the loan or deposit or specified sum so taken or accepted.
(2) Any penalty imposable under sub-section (1) shall be imposed by the Joint Commissioner."
12. Controversy involved in the present appeal lies in a narrow compass, i.e., as to whether or not penalty imposed by the JCIT u/s. 271D of the Act de-hors recording of satisfaction by the A.O for initiating the said penalty proceedings in the body of the assessment order passed u/s. 143(3) dated 25.03.2013 is sustainable in the eyes of law? As is discernible from the assessment order, the A.O in the body of the said order had only initiated penalty u/s. 271(1)(c) of the Act. The issue involved in the present appeal, i.e., sustainability of the penalty imposed u/s. 271D of the Act in absence of any satisfaction for initiating the said penalty proceedings by the A.O in the body of the assessment order is no more res-integra pursuant to the judgment of the Hon'ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City, (2015) 379 ITR 521 (SC). The A.O in the case before the Hon'ble Apex Court had framed the original assessment vide an ex-parte order dated 26.02.1996, determining the income of the assessee at Rs.18.34 lacs (approx.). The A.O while framing the assessment had in the body of the assessment order taken cognizance of the fact that the assessee had contravened the provisions of Section 269SS of the Act and recorded his satisfaction for initiating penalty proceedings u/s. 271D of the Act. On appeal, the CIT(Appeals) set-aside the assessment order with a direction to frame the assessment de-novo after affording an adequate opportunity to the assessee. After remand, the A.O passed a fresh assessment order but failed to record his satisfaction regarding initiation of penalty proceedings u/s. 271D of the Act. During the pendency of the assessee's quantum appeal, which had yet not come up before the CIT(Appeals), the Jt.CIT based on the original assessment order dated 26.02.1996, issued show cause notice to the assessee and imposed penalty u/s. 271D of the Act dated 23.09.1996. It was, thus, in the backdrop of the aforesaid facts that the 8 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 sustainability of the penalty imposed u/s. 271D of the Act based on the original assessment order which did no more survive therein surfaced. On being tested on the touchstone of the fact that the original assessment order wherein, satisfaction for initiating proceedings u/s. 271D of the Act was recorded, having been set-aside, thus, did no more survive, the Tribunal and the High Court concluded that the penalty imposed u/s. 271D of the Act could not be sustained.
13. On further appeal, the Hon'ble Apex Court concluded that as the A.O in the fresh assessment order had not recorded his satisfaction regarding penalty u/s. 271D of the Act, therefore, de-hors recording of requisite satisfaction the penalty imposed u/s. 271D of the Act could not be sustained and was liable to be quashed. For the sake of clarity, the relevant observation of the Hon'ble Apex Court is culled out as under:
"6. As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied."
We find that the aforesaid view taken by the Hon'ble Supreme Court, had, thereafter, been followed by the Hon'ble High Court of Telangana in the case of Shrinivasa Reddy Reddeppagari Vs. JCIT, WP No.44285 of 2022 dated 26.12.2022 wherein the question, for which, indulgence of the Hon'ble High Court was sought, read as under:
"14. Issue raised in the writ petition is whether without satisfaction being recorded in the assessment order, penalty can be levied by the Jt. CIT under S. 271D of the Act?"
Answering the aforesaid question, the Hon'ble High Court after drawing support from the judgment of the Hon'ble Apex Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City (supra), had held as under:
"15. Insofar the present case is concerned, we find that in the assessment order dated 24.03.2022 passed under Section 153A of the Act, return of income filed by the petitioner was accepted by the assessing officer and 9 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 accordingly, the total income was assessed. In the return of income, petitioner had admitted receiving total income of Rs.80,84,180.00 which was also accepted by the assessing officer.
16. Subsequently, respondent No.1 took the view that petitioner had sold immovable properties for a total sale consideration of Rs.92,13,000.00 out of which he had accepted cash to the tune of Rs.87,80,000.00 which was in violation of Section 269SS of the Act, attracting penalty under Section 271D of the Act.
17. Before we advert to the reply submitted by the petitioner, we may mention that under Section 269SS of the Act, no person shall take or accept from any other person (referred to as a depositor) any loan or deposit or any specified sum otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account or through such other electronic mode as may be prescribed, if the amount of such loan or deposit or specified sum is twenty thousand rupees or more. However, as per the first proviso, the rigor of Section 269SS is not applicable to the Government, banking company, post office savings bank or cooperative bank etc. As per the second proviso, this provision would also not be applicable where both the depositor and the receiver are having agricultural income and neither of them has any income chargeable to tax under the Act.
18. Section 271D of the Act deals with penalty for failure to comply with the provisions of Section 269SS of the Act. Section 271D of the Act being relevant is extracted hereunder:
Penalty for failure to comply with the provisions of section 269SS.
271D. (1) If a person takes or accepts any loan or deposit [or specified sum] in contravention of the provisions of section 269SS, he shall be liable to pay, by way of penalty, a sum equal to the amount of the loan or deposit [or specified sum] so taken or accepted.] [(2) Any penalty imposable under sub- section (1) shall be imposed by the [Joint] Commissioner.]
19. Thus, what sub-section (1) of Section 271D provides for is that if a person takes or accepts any loan or deposit or specified amount in contravention of the provisions 10 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 of Section 269SS, he shall be liable to pay by way of penalty, a sum equal to the amount of the loan or deposit or specified sum so taken or accepted. Sub-section (2) clarifies that any penalty imposable under sub-section (1) shall be imposed by the Joint Commissioner.
20. It would be useful to refer to Section 271E of the Act also at this stage which deals with penalty for failure to comply with the provisions of Section 269T of the Act. Be it stated that Section 269T of the Act provides that no branch of a banking company or a cooperative bank and no other company or cooperative society and no firm or other person shall repay any loan or deposit made with it or any specified advance received by it otherwise than by an account payee cheque or account payee bank draft drawn in the name of the person who had made the loan or deposit or who had paid the specified advance or by use of electronic clearing system through a bank account or through such other electronic mode as may be prescribed, if such an amount is twenty thousand rupees or more. As in the case of Section 269SS, Section 269T of the Act also does not apply to the Government, banking company, post office savings bank etc. Section 271E of the Act reads as under:
Penalty for failure to comply with the provisions of section 269T.
271E. [(1)] If a person repays any [loan or] deposit [or specified advance] referred to in section 269T otherwise than in accordance with the provisions of that section, he shall be liable to pay, by way of penalty, a sum equal to the amount of the [loan or] deposit [or specified advance] so repaid.] [(2) Any penalty imposable under sub-section (1) shall be imposed by the [Joint] Commissioner.]
21. Thus, sub-section (1) of Section 271E of the Act provides that if a person repays any loan or deposit or specified advance referred to in Section 269T of the Act otherwise than in accordance with the provisions of that section, he shall be liable to pay by way of penalty a sum equal to the amount of the loan or deposit or specified advance so repaid.
(2) any penalty imposable under sub-section (1) shall be imposed by the Joint Commissioner.
22. From an analysis of Sections 271D and 271E of the Act, it is seen that both the provisions are pari materia to each other. While Section 271D of the Act would be attracted on a person accepting loan or deposit or specified sum in 11 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 contravention of Section 269SS of the Act, penalty under Section 271E of the Act would be imposable on a person who makes or repays the loan or deposit or specified advance in contravention of Section 269T. Therefore, in a way, the two provisions are complimentary to each other.
23. In Jai Laxmi Rice Mills Ambala City (supra), Supreme Court considered the question as to whether penalty proceedings under Section 271D of the Act is independent of the assessment proceeding ? In the facts of that case, it was found that the penalty order was issued following the assessment order. However in appeal, Commissioner of Income Tax (Appeals) had set aside the original assessment order with a direction to frame assessment de novo. In the fresh assessment order, no satisfaction was recorded by the assessing officer regarding initiation of penalty proceedings under Section 271E of the Act. It was noticed that the penalty order was passed before the appeal of the assessee was allowed by the Commissioner of Income Tax (Appeals). It was in that context that Supreme Court held as follows:
The Tribunal as well as the High Court has held that it could not be so for the simple reason that when the original assessment order itself was set aside, the satisfaction recorded therein for the purpose of initiation of the penalty proceeding under Section 271E would also not survive. This according to us is the correct proposition of law stated by the High Court in the impugned order.
As pointed out above, insofar as, fresh assessment order is concerned, there was no satisfaction recorded regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied. These appeals are, accordingly, dismissed.
24. Reverting back to the facts of the present case, we find that petitioner had submitted reply to the show cause notice on 02.06.2022. In his reply, petitioner mentioned that no satisfaction was recorded by the assessing officer in the assessment order as to infraction of Section 269SS of the Act. Therefore, no penalty could be levied under Section 271D of the Act without recorded satisfaction. In this connection, reference was made to the decision of the Supreme Court in Jai Laxmi Rice Mills Ambala City (1 supra) wherein it was clarified that provisions of Section 271E are 12 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 in pari materia with the provisions of Section 271D of the Act. However, this aspect of the matter was not considered by respondent No.1 while passing the impugned order. Respondent No.1 relying upon the Kerala High Court decision in Grihalaxmi Vision (2 supra) noted that competent authority to levy penalty is the Joint Commissioner. He has also referred to an earlier decision of the Supreme Court in CIT V. Mac Data Ltd.3 wherein it was observed that assessing officer has to satisfy himself as to whether penalty proceedings should be initiated or not. Assessing officer is not required to record his satisfaction in a particular manner or reduce it into writing. Therefore, respondent No.1 imposed the penalty under Section 271D of the Act.
25. We are afraid respondent No.1 had completely overlooked the decision of the Supreme Court in Jai Laxmi Rice Mills Ambala City (1 supra). In the said decision as extracted above, Supreme Court had concurred with the view taken by the High Court holding that satisfaction must be recorded in the original assessment order for the purpose of initiation of penalty proceedings under Section 271E of the Act. We have already discussed above that provisions of Section 271E and 271D of the Act are in pari materia. When there is a decision of the Supreme Court, it is the bounden duty of an adjudicating authority, be it an income tax authority or any other civil authority or for that matter any court in the country, to comply with the decision of the Supreme Court.
26. Article 141 of the Constitution of India is clear that law declared by the Supreme Court shall be binding on all courts within the territory of India. This is further clarified in Article 144, which says that all authorities, civil and judicial, in the territory of India shall act in aid of the Supreme Court. We are therefore, of the unhesitant view that respondent No.1 overlooked the relevant considerations while passing the impugned order dated.29.11.2022.
27. Further, issue in the present writ petition is not the competence of the Joint Commissioner in issuing the order of penalty. Therefore, reference to Grihalaxmi Vision (2 supra) was wholly unnecessary.
28. Consequently, we set aside the impugned order dated 29.11.2022 and remand the matter back to the file of respondent No.1 to pass a fresh order in accordance with law after giving a reasonable opportunity of hearing to the petitioner.
13Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026
29. Writ Petition is accordingly allowed. No costs."
14. Also, a similar view had been taken by the Hon'ble High Court of Gujarat in the case of Pr. CIT Vs. Parivar Television, Tax Appeal No.674/2023 dated 09.10.2023, wherein the Hon'ble High Court had approved the view taken by the Tribunal and observed that as no satisfaction regarding initiation of penalty proceedings u/s. 271E of the Act was recorded in the assessment order, therefore, no penalty under the said statutory provision could be levied. Apart from that, we find that similar view had been taken by the ITAT, Hyderabad in the case of ACIT Vs. Bapu Reddy Jala Nizamabad, ITA No.606/Hyd/2022 dated 15.06.2023 and Raja Reddy Nalla Vs. Addl. CIT, ITA No.520/Hyd/2022 dated 31.05.2023 and also by the ITAT, Surat in the case of Parivar Television P. Ltd. Vs. DCIT, ITA No.1738/Ahd/2016 dated 03.01.2023 and by the ITAT, Amritsar in the case of Ram Lubhaya Jassal Vs. Addl. CIT, ITA No.747/Asr/2017 dated 24.09.2021.
15. Considering the fact that the issue before us is no more res-integra in light of the judgment of the Hon'ble Supreme Court in the case of CIT Vs. Jai Laxmi Rice Mills Ambala City (supra), therefore, in the backdrop of our aforesaid deliberations, the penalty imposed by the Jt.CIT u/s. 271D of the Act cannot be sustained and is liable to be struck down for want of valid assumption of jurisdiction."
8. The Hon'ble High Court of Rajasthan in the case of Sunil Agrawal Vs. ACIT, (2025) 172 taxmann.com 54 (Rajasthan) on the similar issue has held and observed as follows:
"6. The reassessment order was passed on 12.03.2024 and no satisfaction was recorded for initiating the penalty proceedings under Section 271E.
7. The reliance on the reference made by the DCIT to ACIT on 01.08.2024 shall not enhance case of the department as the reference was after the conclusion of reassessment proceedings by the DCIT.
8. The satisfaction dated 24.09.2024 recorded by the ACIT cannot be equated with the satisfaction to be recorded in the reassessment proceedings by the concerned A.O. 14 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026
9. In Jai Laxmi Rice Mills Ambala City (supra) the Supreme Court was dealing with the issue as to whether the penalty proceedings under section 271D are independent of the assessment proceedings. In that case, in the assessment order passed in pursuance to the remand no satisfaction was recorded for initiating the proceedings under section 271E. Though the AO stated for initiation of proceedings under section 271(1)(c). The penalty proceeding was quashed on the ground that in absence of satisfaction recorded by the A.O, the penalty cannot be imposed.
10. In the case in hand the DCIT had only recorded satisfaction for proceedings under Section 271(1)(c) of the Act of 1961 and no satisfaction was recorded to initiate penalty proceedings under Section 271D.
11. The issue involved in the present writ petition is squarely covered by the decision of the Supreme Court in Jai Laxmi Rice Mills Ambala City (supra). The notice issued under Section 271E and the proceedings in pursuance thereto are quashed.
12. The writ petitions are allowed."
9. Respectfully following the aforesaid judicial pronouncements, even without going into the merits of the matter on this legal issue itself, appeal of the assessee stands allowed.
10. In the result, appeal of the assessee is allowed.
Order pronounced in open court on 11th day of May, 2026.
Sd/-
(PARTHA SARATHI CHAUDHURY) या यक सद य/JUDICIAL MEMBER रायपुर / Raipur; दनांक / Dated : 11th May, 2026. SB, Sr. PS 15 Vijay Kumar Gupta Vs. ITO, Ward-1(2), Raipur (C.G.) ITA No.310/RPR/2026 आदे श क त ल प अ े षत / Copy of the Order forwarded to :
1. अपीलाथ / The Appellant.
2. यथ / The Respondent.
3. The Pr. CIT-1, Raipur (C.G.)
4. वभागीय त न ध, आयकर अपील य अ धकरण, "एक-सद य" बच, रायपुर / DR, ITAT, "SMC" Bench, Raipur.
5. गाड फ़ाइल / Guard File.
आदेशानुसार / BY ORDER, Samiran Bera,
// True Copy // Sr. PS, ITAT,
Senior Private Secretary Raipur
आयकर अपील य अ धकरण, रायपुर / ITAT, Raipur
Digitally signed by
Samiran Bera, Sr. PS, ITAT,
Raipur
Date: 2026.05.11 16:56:23
+05'30'