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“beneficial owner”

International TaxDTAADTAA951 judgments

The decision most relied on for beneficial owner is Shyam Sunder v. Ram Kumar, (2001) 8 SCC 24 (para 44); Brij Mohan Das Laxman Das v. CIT (5 SCC 482), cited in 261 judgments on BharatTax.

Leading authorities on beneficial owner

Shyam Sunder v. Ram Kumar, (2001) 8 SCC 24 (para 44); Brij Mohan Das Laxman Das v. CIT
5 SCC 482 · 1997 · Supreme Court
261
citing judgments

For income to be assessable under the head 'Income from House Property' as per Section 22 of the Income Tax Act, 1961, beneficial ownership or the right to enjoy the property is sufficient; legal ownership is not a mandatory prerequisite.

Mysore Minerals Ltd. v. CIT
239 ITR 775 · 1999 · Supreme Court
215
citing judgments

For income tax purposes, the 'owner' of a property is the person who is entitled to receive income in their own right, bears the risks incidental to ownership, and utilizes the asset, even if the sale deed is not formally registered. This beneficial ownership is sufficient for claiming depreciation or capital gains exemption under relevant sections.

CIT v. Ankitech (P) Ltd.
340 ITR 14 · 2012 · High Court
202
citing judgments

Deemed dividend under section 2(22)(e) cannot be taxed in the hands of a non-shareholder. The Supreme Court confirmed this view, affirming the Delhi High Court's decision in Ankitech.

PCIT v. Ambe Tradecorp Pvt. Ltd.
145 Taxmann.com 27 · 2022 · High Court
169
citing judgments

No addition under section 68 can be made for a loan if the assessee furnishes material proving the identity of the loan givers, demonstrates they are not the beneficial owner, and has repaid the loan in a subsequent year.

CIT v. Universal Medicare Pvt. Ltd.
324 ITR 263 · 2010 · High Court
111
citing judgments

Deemed dividend under section 2(22)(e) is assessable only in the hands of the beneficial shareholder who receives the benefit of the loan or advance, and not in the hands of the company receiving the loan.

Miss P. Sarada v. CIT
229 ITR 444 · 1998 · Supreme Court
64
citing judgments

A loan or advance from a closely held company to a shareholder is a deemed dividend under Section 2(22)(e) upon receipt, unaffected by subsequent repayment or adjustment.

(Refer: CIT v. C.P.Sarathy Mudaliar
83 ITR 170 · 1972 · Supreme Court
63
citing judgments

For the purpose of deemed dividend under section 2(22)(e) of the Income-tax Act, the term 'shareholder' refers exclusively to a registered shareholder of the company, and not a beneficial owner or non-shareholder.

CIT v. Ravinder Kumar Arora
342 ITR 38 · 2012 · High Court
51
citing judgments

Deduction under Section 54F cannot be restricted or denied merely because the new residential property, for which the entire consideration is paid by the assessee, is purchased in the joint names of the assessee and their spouse. The assessee is considered the actual and constructive owner of the property.

Judgments citing beneficial owner

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 736/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 735/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 734/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 733/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 732/CHNY/2022[2008-2009]Status: DisposedITAT Chennai21 Jan 2026AY 2008-2009

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 730/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 729/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 728/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 727/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners ... fact that the power of attorneys were registered document and that the appellant company was acting as a power agent of the real and beneficial owner of the land. 6. The Ld. CIT(A) and Ld. Assessing Officer erred by treating the land sold on behalf of land owners

Deputy Commissioner of Income Tax, Delhi vs. Ravi Bharadwaj, Delhi

In the result, the appeal filed by the Revenue for the AY 2013-14 is dismissed

ITA 2232/DEL/2025[2013-14]Status: DisposedITAT Delhi21 Jan 2026AY 2013-14

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri V.K. Agarwal, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 142(1)Section 143

present case as there was enough incriminating material which was found during the search operation which established that Sh. Ravi Bharadwaj was the beneficial owner of bank accounts of Lazare International Group Limited. (ii) The Ld. CIT(A) has erred in appreciating the facts and circumstances of the, case

Deputy Commissioner of Income Tax, Delhi vs. Ravi Bharadwaj, Delhi

In the result, the appeal filed by the Revenue for the AY 2013-14 is dismissed

ITA 2231/DEL/2025[2012-13]Status: DisposedITAT Delhi21 Jan 2026AY 2012-13

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri V.K. Agarwal, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 142(1)Section 143

present case as there was enough incriminating material which was found during the search operation which established that Sh. Ravi Bharadwaj was the beneficial owner of bank accounts of Lazare International Group Limited. (ii) The Ld. CIT(A) has erred in appreciating the facts and circumstances of the, case

Deputy Commissioner of Income Tax, Delhi vs. Ravi Bharadwaj, Delhi

In the result, the appeal filed by the Revenue for the AY 2013-14 is dismissed

ITA 2230/DEL/2025[2011-12]Status: DisposedITAT Delhi21 Jan 2026AY 2011-12

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri V.K. Agarwal, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 132Section 142(1)Section 143

present case as there was enough incriminating material which was found during the search operation which established that Sh. Ravi Bharadwaj was the beneficial owner of bank accounts of Lazare International Group Limited. (ii) The Ld. CIT(A) has erred in appreciating the facts and circumstances of the, case

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

Appeal of the revenue is dismissed and cross objection is partly allowed

ITA 1592/KOL/2025[2017-18]Status: DisposedITAT Kolkata20 Jan 2026AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 133ASection 143(1)Section 250Section 68

tained in course of Survey proceedings. Only on the basis of these depositions, the AO and CIT(A) has held the assessee to be beneficial owner of such entities. We also note that the assessee when confronted with these statements never admitted that the offshore entities were con- trolled

Kyocera Document Solutions Asia Limited (Formerly Known As Kyocera Mita Asia Limited), Hongkong vs. Assistant Commissioner of Income Tax, Circle Intt Tax 2(1)(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1664/DEL/2025[2022-23]Status: DisposedITAT Delhi13 Jan 2026AY 2022-23

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

services may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the Page 22 of 27 ITA No. 380, 3546/DEL/2023 & 1664/DEL/2025 [A.Y 2020-21, 2021-22 & 2022-23] Kyocera Document Solutions Asia Vs. ACIT

Kyocera Document Solutions Asia Limited, Hong Kong vs. ACIT Circle Int Tax 2(1)(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 380/DEL/2023[2020-21]Status: DisposedITAT Delhi13 Jan 2026AY 2020-21

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

services may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the Page 22 of 27 ITA No. 380, 3546/DEL/2023 & 1664/DEL/2025 [A.Y 2020-21, 2021-22 & 2022-23] Kyocera Document Solutions Asia Vs. ACIT

Kyocera Document Solutions Asia Ltd., (Formerly Known As Kyocera Mita Asia Limited), Hong Kong vs. ACIT, Circle International Tax 2(1)(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 3546/DEL/2023[2021-22]Status: DisposedITAT Delhi13 Jan 2026AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Nethrapal, CIT-DR
Section 143(3)

services may also be taxed in the Contracting Party in which they arise, and according to the laws of that Party, but if the beneficial owner of the Page 22 of 27 ITA No. 380, 3546/DEL/2023 & 1664/DEL/2025 [A.Y 2020-21, 2021-22 & 2022-23] Kyocera Document Solutions Asia Vs. ACIT

Jag Mohan, Delhi vs. DCIT, Central Circle- 18, New Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 7055/DEL/2017[2014-15]Status: DisposedITAT Delhi07 Jan 2026AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.7055/धिल्ली/2017(नि.व. 2014-15) Jag Mohan, 354, Tarun Enclave, Pitampura, ...... अपीलार्थी/Appellant Delhi 110034 Pan Ahdpm-3671-M बिाम Vs. Deputy Commissioner Of Income Tax, ..... प्रनिवादी/Respondent Circle-18, New Delhi अपीलार्थी द्वारा/ Appellant By : S/Shri Raghav Sharma, Mohit Gupta, Chartered Accountants & Ms. Chandrima Choudhary, Advocate प्रधिवािीद्वारा/Respondent By : Ms. Namita Khurana Cit-Dr & Shri Om Prakash, Sr.Dr सुिवाई की निथर्थ/ Date Of Hearing : 10/10/2025 घोषणा की निथर्थ/ Date Of Pronouncement: 07/01/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-28, New Delhi [In Short ‘The Cit(A)’] Dated 18/09/2017, For Assessment Year 2014-15. 2. A Search & Seizure Operation U/S.132 Of The Income Was Conducted On 26.08.2013 In The Case Of Mohan India Group. The Assessee Is One Of The Directors Of Mohan India Group & The Assessee Was Also Covered Under Said Search. During

For Appellant: S/Shri Raghav Sharma, Mohit Gupta, CharteredFor Respondent: Ms. Namita Khurana CIT-DR &
Section 132Section 143(3)Section 153A

purchaser was not disclosed in the statement. At the same time, no enquiry was conducted by the Assessing Officer to find the name of beneficial owner of the remaining five properties at Sr. No. 2 to 6. There is no positive finding of fact by the AO that ... properties mentioned in the above table are in the name of the assessee or the assessee is the beneficial owner of any of the above properties. 14. We find that the AO in the assessment order has observed that, “from perusal of the bank statement it was seen that

ACIT Circle-1, Dhanbad vs. M/S Bharat Cooking Coal Ltd, Dhanbad

ITA 302/RAN/2017[11-12]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M Vs. Acit, Circle-1, Dhanbad & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / Order Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

For Appellant: Shri M.K.ChowdharyFor Respondent: Shri Rajib Jain, CIT-DR
Section 143(3)Section 14ASection 300Section 32(2)

आयकर अपीलीय अधिकरण, राँची न्यायपीठ, राँची IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JM

ACIT Cir-1, Dhanbad vs. M/S Bharat Cooking Coal Ltd, Dhanbad

ITA 300/RAN/2017[09-10]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Hon'Ble Itat - By It Department Si No.

Section 1Section 143(3)Section 14ASection 32(2)

M/s Bharat Coking Coal Ltd. 2 12 & 2012-13, respectively. The assessee has also filed cross objections arising out of

M/S Bharat Cooking Coal Limited, Dhanbad vs. ACIT Cir-1, Dhanbad

In the result, both appeals of revenue and the cross objections of the assessee are dismissed and appeals of assessee in ITA No

ITA 291/RAN/2017[09-10]Status: DisposedITAT Ranchi06 Jan 2026

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011-

For Appellant: Shri M.K.ChowdharyFor Respondent: Shri Rajib Jain, CIT-DR
Section 32(2)

businesses of several persons. d. that Sri Lal Bahadur Singh admitted that these persons were his conduits and that he was the beneficial owner of all these businesses (see 12 to 17 of the assessment order). e. that there were 101 such entities (24+77) which had received contract payments ... filed an application before the settlement Commission. h. that majority of the payments were made to the group entities (of which he was the beneficial owner) at the fag end of the FY. i. that for the AY 2011-12, before the Settlement Commission, Sri L B Singh offered