Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna
In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed
ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21
Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025
For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C
…from third party cannot be sustained. This is more particularly so when the appellant has consistently and categorically denied any such transactions. The appellant is supported by the series of judicial pronouncements, which is as under- 1) CIT v. Sant Lal [317 CTR 483 (Del))- In this case, the department relied upon the notings of hundi in the diary seized from the premises of third party. The said notings allegedly contained entries of hundi transactions on behalf of parties including assessee whose names. were written in abbreviated/code words. The Hon'ble Delhi High Court relying on its earlier decision in…
