ITAT Patna Judgments — September 2025

SRI TRIPURARI MOHAN PRASAD,PATNA vs ACIT, PATNA

ITA 90/PAT/2013[1993-94]Status: Disposed4 Sept 2025AY 1993-94Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTIVALS (P) LTD.,PATNA vs ACIT, PATNA

ITA 100/PAT/2013[1987-88]Status: Disposed4 Sept 2025AY 1987-88Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTICALS (P) LTD.,PATNA vs ACIT, PATNA

ITA 103/PAT/2013[1990-91]Status: Disposed4 Sept 2025AY 1990-91Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI SUSHIL KUMAR,PATNA vs ACIT, PATNA

ITA 93/PAT/2013[1988-89]Status: Disposed4 Sept 2025AY 1988-89Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI TRIPURARI MOHAN PRASAD,PATNA vs ACIT, PATNA

ITA 83/PAT/2013[1986-87]Status: Disposed4 Sept 2025AY 1986-87Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SUSHIL KUMAR,PATNA vs ACIT, CENTRAL CIRCLE-1, PATNA

ITA 97/PAT/2013[1992-93]Status: Disposed4 Sept 2025AY 1992-93Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTICALS (P) LTD.,PATNA vs ACIT, PATNA

ITA 105/PAT/2013[1992-93]Status: Disposed4 Sept 2025AY 1992-93Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTIVALS (PVT.),PATNA vs ACIT, PATNA

ITA 176/PAT/2013[1995-96]Status: Disposed4 Sept 2025AY 1995-96Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTICALS (P) LTD.,PATNA vs ACIT, PATNA

ITA 106/PAT/2013[1993-94]Status: Disposed4 Sept 2025AY 1993-94Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MASTRIN PHARMACEUTICALS (P) LTD.,PATNA vs ACIT, PATNA

ITA 102/PAT/2013[1989-90]Status: Disposed4 Sept 2025AY 1989-90Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI TRIPURARI MOHAN PRASAD,PATNA vs ACIT, PATNA

ITA 89/PAT/2013[1992-93]Status: Disposed4 Sept 2025AY 1992-93Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI SUSHIL KUMAR,PATNA vs ACIT, PATNA

ITA 91/PAT/2013[1986-87]Status: Disposed4 Sept 2025AY 1986-87Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI TRIPURARI MOHAN PRASAD,PATNA vs ACIT, PATNA

ITA 87/PAT/2013[1990-91]Status: Disposed4 Sept 2025AY 1990-91Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI SUSHIL KUMAR,PATNA vs ACIT, PATNA

ITA 95/PAT/2013[1990-91]Status: Disposed4 Sept 2025AY 1990-91Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SRI TRIPURARI MOHAN PRASAD,PATNA vs ACIT, PATNA

ITA 86/PAT/2013[1989-90]Status: Disposed4 Sept 2025AY 1989-90Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

M/S. MANAS SALES CORPORATION,PATNA vs ACIT, PATNA

ITA 171/PAT/2013[1989-90]Status: Disposed4 Sept 2025AY 1989-90Partly Allowed

The Tribunal noted that the issue regarding the validity of notices issued under Section 148 during incarceration was not argued before the lower authorities or the CIT(A). The facts were not emanating from the orders of the authorities below.

M/S MANAS SALES CORPORATION,PATNA vs ACIT, CENTRAL CIRCLE-1, PATNA

ITA 170/PAT/2013[1988-89]Status: Disposed4 Sept 2025AY 1988-89Partly Allowed

The Tribunal noted that the issue regarding the validity of notices issued under Section 148 during incarceration was not argued before the lower authorities or the CIT(A). The facts were not emanating from the orders of the authorities below.

M/S. MANAS SALES CORPORATION,PATNA vs ACIT, PATNA

ITA 172/PAT/2013[1992-93]Status: Disposed4 Sept 2025AY 1992-93Partly Allowed

The Tribunal noted that the issue regarding the validity of notices issued under Section 148 during incarceration was not argued before the lower authorities or the CIT(A). The facts were not emanating from the orders of the authorities below.

SRI SUSHIL KUMAR,PATNA vs ACIT, PATNA

ITA 98/PAT/2013[1993-94]Status: Disposed4 Sept 2025AY 1993-94Partly Allowed

The Tribunal noted that the issue of notices being bad in law due to the assessee's incarceration was not argued before the CIT(A) or lower authorities, and the facts were not emanating from their orders. Therefore, the Tribunal decided that the issue needed to be adjudicated first by the CIT(A) after considering all facts.

SACHIN YADAV,PATNA vs DCIT, CENTRAL CIRCLE 3 PATNA , PATNA

ITA 348/PAT/2024[2005-06]Status: Disposed4 Sept 2025AY 2005-06Partly Allowed

The Tribunal observed that the CIT(A) had passed an ex parte order without giving the assessee a sufficient opportunity to be heard. Therefore, in the interest of justice, the assessee was granted one more opportunity to substantiate their claim before the CIT(A) by restoring the issues for fresh adjudication.

RD ECO DEVELOPERS PVT. LTD,PATNA vs DCIT, CIRCLE-1, PATNA

ITA 312/PAT/2025[2020-21]Status: Disposed4 Sept 2025AY 2020-21Partly Allowed

The appeal is restored to the file of the Assessing Officer for re-adjudication to grant the assessee an adequate opportunity of being heard. A cost of Rs. 50,000/- is imposed on the assessee for non-cooperation.

SUMAN DEVI,PATNA vs INCOME TAX OFFICER, PATNA

ITA 210/PAT/2025[2014-15]Status: Disposed4 Sept 2025AY 2014-15Allowed

The Tribunal held that the provisions of Section 2(47) of the Act, related to transfer of immovable property and capital gains computation, do not apply to a case of purchase. Since the purchase consideration was paid during AY 2013-14, it cannot be questioned in AY 2014-15. Therefore, the addition made by the Assessing Officer and confirmed by the CIT(A) was deleted.

M/S. MANAS SALES CORPORATION,PATNA vs ACIT, PATNA

ITA 173/PAT/2013[1993-94]Status: Disposed4 Sept 2025AY 1993-94Partly Allowed

The Tribunal noted that the issue regarding the validity of notices issued under Section 148 during incarceration was not argued before the lower authorities or the CIT(A). The facts were not emanating from the orders of the authorities below.

RANJAN KUMAR SHARMA,EAST CHAMPARAN vs ASSESSMENT UNIT PTN-W-(27)(2) INCOME TAX DEPARTMENT, DELHI

ITA 64/PAT/2025[2018-19]Status: Disposed2 Sept 2025AY 2018-19Partly Allowed

The Tribunal condoned the delay of 85 days, stating that the assessee had provided a reasonable cause. However, due to the contumacious attitude of the assessee in not appearing before the lower authorities, the appeal was restored to the Assessing Officer for readjudication with a cost of Rs. 1,00,000 to be paid to the Bihar State Legal Services Authority.

MD RIZWAN,PATNA vs CIT(A), PATNA

ITA 390/PAT/2024[1985-86]Status: Disposed2 Sept 2025AY 1985-86Dismissed

The Tribunal held that the assessee failed to demonstrate that the disputed amount was already incorporated in the total purchases and thus could not prove it was a double addition. The assessee was unable to explain the amount, and no reason was found to interfere with the CIT(A)'s order.

ROHIT KUMAR DAS,KATIHAR vs ITO , KATIHAR

ITA 624/PAT/2024[2018-19]Status: Disposed2 Sept 2025AY 2018-19Partly Allowed

The Tribunal condoned the delay of 17 days in filing the appeal, being satisfied with the assessee's reasonable cause. The appeal was restored to the CIT(A) for readjudication.

DBS AUTOMOBILES PVT. LTD.,PATNA vs ACIT, CIR-1, PATNA, PATNA

ITA 203/PAT/2025[2017-18]Status: Disposed2 Sept 2025AY 2017-18Remanded

The Tribunal held that the assessee was not provided adequate time to furnish the information requested by the AO. Therefore, in the interest of justice, the matter was restored to the AO for readjudication.

PAVAN KUMAR BHAGAT,SAHARSA vs ITO, WARD-3(4), SAHARSA, SAHARA

ITA 281/PAT/2024[2017-18]Status: Disposed2 Sept 2025AY 2017-18Allowed

The Tribunal found that the assessment order was made ex parte and the appeal before the CIT(A) was also decided ex parte. The Tribunal considered it appropriate to provide the assessee with another opportunity to represent their case properly.

SANJAY KUMAR SINHA,SAMASTIPUR vs ITO, WARD- 3 (3), SAMASTIPUR

ITA 260/PAT/2025[2017-18]Status: Disposed2 Sept 2025AY 2017-18Partly Allowed

The issues in the appeal are restored to the file of the Id CIT(A) for readjudication, with a cost of Rs.10,000 to be paid to the Bihar State Legal Services Authority within 60 days. The assessee is also directed to produce evidence before the Id CIT(A).

CHANDA SINGH,KATIHAR vs ACIT, CENTRAL CIRCLE-3, PATNA

ITA 127/PAT/2025[2019-20]Status: Disposed2 Sept 2025AY 2019-20Remanded

The Tribunal found that the assessee had submitted new documentary evidence regarding payments made in earlier years. Due to the discrepancy between the payment dates and the property registration date, and the need for further verification, the case was remitted back to the Assessing Officer.

HYGIENIC PRODUCTS FOR COMMON CITIZENS,MADHEPURA vs ITO WARD 3(4), SAHARSA, SAHARSA

ITA 141/PAT/2025[2019-2020]Status: Disposed2 Sept 2025AY 2019-2020Remanded

The Tribunal noted that the assessee had failed to make proper representation at both the assessment stage before the AO and the appellate stage before the NFAC. The NFAC's order indicated that adequate opportunities were given to the assessee, but there was non-compliance and no documents were produced. The Tribunal, in the interest of justice and fair play, deemed it appropriate to provide another opportunity to the assessee. Therefore, the Tribunal set aside the orders of both the NFAC and the AO. The matter was remitted back to the AO to be decided afresh, with the direction that the AO shall allow an opportunity of being heard and representing the case to the assessee. The assessee was cautioned against seeking unnecessary adjournments. The grounds of appeal raised by the assessee were allowed for statistical purposes.

SANJEEV KUMAR,PATNA vs ITO, WARD- 6 (1), PATNA

ITA 264/PAT/2025[2014-15]Status: Disposed1 Sept 2025AY 2014-15Remanded

The Tribunal noted a delay of 56 days in filing the appeal and condoned it after finding reasonable cause. The Tribunal found that the CIT(A) dismissed the appeal ex-parte without going into merits, which is contrary to law.

BHAGWAN BHASKAR MAHILA UTTHAN SAMITI, THROUGH PRESIDENT RANA PRATAP SINGH,AURANGABAD vs CIT EXEMPTION, PATNA

ITA 305/PAT/2025[2025-26]Status: Disposed1 Sept 2025AY 2025-26Remanded

The Tribunal noted that the assessee had submitted the trust deed, which was allegedly not considered by the CIT(E). The CIT(E)'s order was based on the belief that the assessee failed to provide relevant documents to prove its bonafides.

RUBI KUMARI,SAMASTIPUR vs ITO, WARD- 3 (3), SAMASTIPUR

ITA 263/PAT/2025[2017-18]Status: Disposed1 Sept 2025AY 2017-18Remanded

The Tribunal found that the CIT(A) passed an ex-parte order without examining the merits of the case, which is contrary to law. Therefore, the matter was remanded back to the CIT(A) for a fresh examination.

DCIT, CIRCLE-4, PATNA, DAKBANGLOW CHAURAHA PATNA vs KRISHNA SEEDS, SP VERMA ROAD PATNA

ITA 164/PAT/2025[2014-15]Status: Disposed1 Sept 2025AY 2014-15N/A

The Tribunal set aside the order of the CIT(A) and restored the issue of disallowance under section 40(a)(ia) to the Assessing Officer for fresh readjudication. Consequently, the cross-objections filed by the assessee (C.O. Nos. 6 & 7) were also dismissed as infructuous.

ACIT, CIRCLE-4, PATNA vs M/S KRISHNA SEEDS, PATNA

ITA 138/PAT/2019[2014-15]Status: Disposed1 Sept 2025AY 2014-15Partly Allowed

The appeal filed by the revenue in ITA No.138/Pat/2019 was partly allowed for statistical purposes. The identical appeal in ITA No.164/Pat/2025 was dismissed as infructuous, and the cross objections were also dismissed as infructuous.

VISHNU KANT GUPTA,EAST CHAMPARAN vs ACIT, CENTRAL CIRCLE, MUZAFFARPUR

ITA 83/PAT/2025[2015-16]Status: Disposed1 Sept 2025AY 2015-16Partly Allowed

The grounds raised by the assessee were allowed for statistical purposes. The appeals of the assessee were partly allowed for statistical purposes.

VISHNU KANT GUPTA,EAST CHAMPARAN vs ACIT, CENTRAL CIRCLE, MUZAFFARPUR

ITA 85/PAT/2025[2017-18]Status: Disposed1 Sept 2025AY 2017-18Partly Allowed

The grounds raised by the assessee were allowed for statistical purposes. The appeals of the assessee were partly allowed for statistical purposes.

VISHNU KANT GUPTA,EAST CHAMPARAN vs ACIT, CENTRAL CIRCLE, MUZAFFARPUR

ITA 84/PAT/2025[2016-17]Status: Disposed1 Sept 2025AY 2016-17Partly Allowed

The grounds raised by the assessee were allowed for statistical purposes. The appeals of the assessee were partly allowed for statistical purposes.

BIPIN KUMAR,VAISHALI vs ITO WARD 1(3), VAISHALI

ITA 463/PAT/2024[2017-18]Status: Disposed1 Sept 2025AY 2017-18Allowed

The Tribunal noted that the CIT(A) had passed an ex-parte order due to non-compliance by the assessee. However, considering the interest of substantial justice, the Tribunal decided to grant one final opportunity to the assessee.

GIRISH CHANDRA,PATNA vs ITO, WARD- 4(3), PATNA

ITA 615/PAT/2024[2016-17]Status: Disposed1 Sept 2025AY 2016-17Allowed

The Tribunal noted a delay of 253 days in filing the appeal, which was condoned due to reasonable cause. The CIT(A) had dismissed the appeal ex parte because the assessee failed to appear or file submissions. The Tribunal set aside the CIT(A)'s order and restored the matter to provide the assessee one final opportunity to present their case.

NARENDRA KUMAR KHATRI,PATNA vs ITO, WARD- 5 (3), PATNA

ITA 307/PAT/2025[2014-15]Status: Disposed1 Sept 2025AY 2014-15Allowed

The Tribunal acknowledged that the assessee did not receive notices due to technical issues with their email and there was no malafide intention. The Tribunal condoned the delay of 801 days and restored the appeal to the CIT(A) for fresh adjudication, emphasizing the principle of natural justice.

SANJAY KUMAR SHARMA,BHAGALPUR vs PCIT-1, PATNA

ITA 209/PAT/2025[2013-14]Status: Disposed1 Sept 2025AY 2013-14Allowed

The tribunal found that the ex-parte order by the CIT(A) due to non-compliance was not justified. The assessee was granted one more opportunity to explain and substantiate their case before the CIT(A) for fresh adjudication.

SAMASTIPUR KSHETRIYA GRAMIN BANK,PATNA vs DCIT, CIRCLE-3, DARBHANGA

ITA 32/PAT/2019[2010-11]Status: Disposed1 Sept 2025AY 2010-11Allowed

The Tribunal held that the penalty order was passed after the statutory limitation period, specifically after August 31, 2013, which was the prescribed deadline for imposing penalties under section 271(1)(c) of the Act.

VISHNU KANT GUPTA,EAST CHAMPARAN vs ACIT, CENTRAL CIRCLE, MUZAFFARPUR

ITA 82/PAT/2025[2001-02]Status: Disposed1 Sept 2025AY 2001-02Partly Allowed

The grounds raised by the assessee were allowed for statistical purposes. The appeals of the assessee were partly allowed for statistical purposes.

DINESHWAR PRASAD,SARVADYA KAMLA APARTMENT, BORING ROAD vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4, PATNA, NOT KNOWN

ITA 250/PAT/2025[2014-15]Status: Disposed1 Sept 2025AY 2014-15Allowed

The Tribunal condoned the 749-day delay in filing the appeal, finding reasonable cause. The Tribunal set aside the CIT(A)'s ex parte order and restored the matter for a fresh adjudication, granting the assessee one last opportunity to present their case.

ABINASH JHA,PATNA vs ITO WARD 4(5), PATNA

ITA 220/PAT/2023[2016-17]Status: Disposed1 Sept 2025AY 2016-17Remanded

The Tribunal noted that the CIT(A) had dismissed the appeal ex parte without considering the merits of the case, which was contrary to law. Therefore, the Tribunal decided to remand the matter back to the Assessing Officer for a fresh examination, with a direction to provide the assessee with a reasonable opportunity of being heard.

VISHNU KANT GUPTA,EAST CHAMPARAN vs ACIT, CENTRAL CIRCLE, MUZAFFARPUR

ITA 86/PAT/2025[2018-19]Status: Disposed1 Sept 2025AY 2018-19Partly Allowed

The grounds raised by the assessee were allowed for statistical purposes. The appeals of the assessee were partly allowed for statistical purposes.