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“rule 46A”

AppealsRule 46ARule 46A2,967 judgments

The decision most relied on for rule 46A is CIT v. Divine Leasing & Finance Ltd. (299 ITR 268), cited in 426 judgments on BharatTax.

Leading authorities on rule 46A

CIT v. Divine Leasing & Finance Ltd.
299 ITR 268 · 2008 · High Court
426
citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Smt. Prabhavati S. Shah v. CIT
231 ITR 1 · 1998 · High Court
186
citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

CIT v. Manish Build Well (P) Ltd.
16 Taxmann.com 27 · 2011 · High Court
120
citing judgments

The CIT(A) must strictly comply with Rule 46A of the Income-tax Rules for admitting additional evidence, ensuring all prescribed conditions exist, reasons are recorded, and reasonable opportunity is provided to the Assessing Officer.

CIT v. Nikunj Eximp
216 Taxmann.com 171 · 2013 · High Court
103
citing judgments

The Assessing Officer must consider additional evidence produced before the CIT(A) under Rule 46A and cannot reject it without proper appreciation of the facts, especially when the assessee was prevented by sufficient cause from producing it earlier.

CIT v. Virgin Securities & Credits (P) Ltd.
332 ITR 396 · 2011 · High Court
85
citing judgments

The Commissioner of Income-tax (Appeals) must admit additional evidence if it is crucial for the proper disposal of the appeal, ensuring substantial justice to the appellant.

CIT v. Manish Buildwell (P) Ltd.
245 CTR 397 · 2011 · High Court
58
citing judgments

The production of fresh evidence at the appellate stage before the Commissioner (Appeals) is strictly governed by the conditions and procedures laid down in Rule 46A of the Income-tax Rules.

CIT v. Ranjit Kumar Choudhury
288 ITR 179 · 2007 · High Court
55
citing judgments

The appellate authority must follow Rule 46A of the Income Tax Rules when admitting additional evidence, which includes recording reasons for admission and providing the Assessing Officer an opportunity to verify or refute the evidence. Failure to do so violates principles of natural justice.

Judgments citing rule 46A

DCIT, New Delhi vs. Omax Autos Ltd, Gurgaon

ITA 3055/DEL/2025[2020-21]Status: DisposedITAT Delhi14 Jan 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)Section 43(6)Section 45

Extensive written submissions were filed by the ld. AR and same have all the relevant facts and only contention of ld. DR was that Rule 46A for admitting additional evidences was not followed. Same shall be addressed at appropriate as we intend to first consider issues and relevant evidences

Assistant Commissioner of Income Tax, Delhi vs. 21St Century E-Solutions Private Limited, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 120/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Sushil Kumar Gupta, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133(6)Section 250Section 68

ACIT VS 21ST CENTURY E-SOLUTIONS 3.1 Aggrieved, the assessee preferred an appeal before Ld. CIT(A). The assessee filed additional evidence under Rule 46A and submitted that sufficient time was not given by the Ld. AO for submitting relevant documentary evidences to prove the creditworthiness of the parties

Jitubhai Shamaldas Tokle, Bhavnagar vs. The ITO, Ward-1(10), Bhavnagar

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2385/AHD/2025[2022-23]Status: HeardITAT Ahmedabad13 Jan 2026AY 2022-23

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblejitubhai Shamaldas Tokle, Income Tax Officer, Vs. Prop. Tokle Timbers, Ward 1(10), Plot No. 89/1, Ferry Road, Bhavnagar Juna Bunder, Bhavnagar-364 001 [Pan : Acspt 8928 Q] (Appellant) .. (Respondent) Appellant Represented By : Shri Mehul K. Patel, Advocate Respondent Represented By: Shri Virbhadra Vishalavat, Sr. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 13.01.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

Section 250Section 69

appeal :- “(1) That on facts, and in law, the learned NFAC has grievously erred in not admitting the additional evidence in terms of Rule 46A of the IT Rules. (2) That on facts, and in law, the learned NEAC has grievously erred in confirming the addition of Rs.31

Jamal Mohamed Haroon Hassan Moulana, Chennai vs. ITO, Ncw-1(1), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2559/CHNY/2025[2021-22]Status: DisposedITAT Chennai13 Jan 2026AY 2021-22

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2559/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

For Appellant: Mr. Raghav Rajeev Menon &For Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 250Section 44ASection 69A

Moulana. :- 4 -: submitted that the assessee has submitted the documentary evidences explaining the source of cash before the CIT(A) though no petition under Rule 46A was submitted. The Ld. AR therefore prayed for one more opportunity to represent the case properly before the lower authorities. Considering the facts

ITO 19.3.1, Mumbai vs. Raashi Sawhney, Mumbai

ITA 7091/MUM/2025[2015-16]Status: DisposedITAT Mumbai13 Jan 2026AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Shri Nimesh AgarwalFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 144Section 147Section 234ASection 234BSection 69

admission of documentary evidence other than the evidence produced during the course of proceedings before the assessing officer, has been filed in terms of Rule 46A should have been remanded to the AO under the provisions of the Act 2. "Whether on the facts and in the circumstances ... this regard, it was submitted that it is not clear from the impugned order as to whether the assessee has moved any application under Rule 46A of the Income Tax Rules, 1962 (‘the Rules’) before the Ld.CIT(A), NFAC, Delhi and acceptance thereof, in absence of any findings

ITO 19.3.1, Mumbai vs. Raashi Sawhney, Mumbai

ITA 7090/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Shri Nimesh AgarwalFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 144Section 147Section 234ASection 234BSection 69

admission of documentary evidence other than the evidence produced during the course of proceedings before the assessing officer, has been filed in terms of Rule 46A should have been remanded to the AO under the provisions of the Act 2. "Whether on the facts and in the circumstances ... this regard, it was submitted that it is not clear from the impugned order as to whether the assessee has moved any application under Rule 46A of the Income Tax Rules, 1962 (‘the Rules’) before the Ld.CIT(A), NFAC, Delhi and acceptance thereof, in absence of any findings

ITO, Mumbai vs. Raashi Sawhney, Mumbai

ITA 7089/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Shri Nimesh AgarwalFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 144Section 147Section 234ASection 234BSection 69

admission of documentary evidence other than the evidence produced during the course of proceedings before the assessing officer, has been filed in terms of Rule 46A should have been remanded to the AO under the provisions of the Act 2. "Whether on the facts and in the circumstances ... this regard, it was submitted that it is not clear from the impugned order as to whether the assessee has moved any application under Rule 46A of the Income Tax Rules, 1962 (‘the Rules’) before the Ld.CIT(A), NFAC, Delhi and acceptance thereof, in absence of any findings

ACIT-1(1), Indore vs. Kriti Nutrients Limited, Indore

The appeal of the Revenue is allowed for statistical

ITA 780/IND/2024[2021-22]Status: DisposedITAT Indore09 Jan 2026AY 2021-22

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 246ASection 250Section 253

approach is not permissible in law. The Ld. DR for the revenue further submitted that the Ld. CIT(A) without appreciating the applicability of Rule 46A in its correct perspective has blindly accepted the plea of the assessee company u/r 46A. The purpose of Rule 46A is not appreciated ... filed the remand report within the meaning Page 31 of 107 Kriti Nutrients Ltd. ITA No. 780/Ind/2024 A.Y. 2021-22 the Rule 46A that ipso fact does not means that the additional evidence u/r 46A should be admitted & accepted that too blindly. Rule 46A is statutory & mandatory in nature. Effective

Harjeet Kaur, Uttar Pradesh vs. Circle 5(1)(1), G B Nagar, Uttar Pradesh

The appeal is allowed and the

ITA 2731/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalharjeet Kaur Vs. Circle 5(1)(1) S-004, F Block, Omax Income Tax Department Queen, Gautam Buddha Gb Nagar Nagar, Uttar Pradesh Uttar Pradesh – 201307 201301 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Azzpk6790P Appellant .. Respondent

For Appellant: Sh. Ravi Pratap Mall, AdvFor Respondent: Ms. Pooja Swaroop, CIT, DR
Section 144Section 68

principles of natural justice.” 5. On hearing both sides at length we find that assessee had filed additional evidences by taking recourse to Rule 46A and remand report dated 25.07.2024 was received by the CIT(A) and thereby the CIT(A) instead of P a g e | 5 Harjeet Kaur ... taking into consideration the aforesaid facts and circumstances we find substance in the contention of ld. Counsel that once assessee has taken recourse of Rule 46A of the Income Tax Rules 1962 and Assessing Officer was called upon to file remand report and who after verification filed elaborate remand report

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

vide dated 20-02-2021 at the time of assessment proceedings. 2.1 That on the facts and circumstances of the case, provision of the Rule-46A of Income Tax Rule 1962 is not applicable as all the evidences has been submitted before Ld. AO in the assessment proceedings. 3.0 That ... No.1807/Del/2010 dated 29.08.2012 wherein the Co-ordinate Bench has set aside the order of Ld. CIT(A) passed in the light of Rule-46A(3) of the IT Rules, 1962. He prayed accordingly. 25. On the other hand, the Ld. AR of the assessee vehemently supported the orders

DCIT Circle 4(2), New Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2330/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

vide dated 20-02-2021 at the time of assessment proceedings. 2.1 That on the facts and circumstances of the case, provision of the Rule-46A of Income Tax Rule 1962 is not applicable as all the evidences has been submitted before Ld. AO in the assessment proceedings. 3.0 That ... No.1807/Del/2010 dated 29.08.2012 wherein the Co-ordinate Bench has set aside the order of Ld. CIT(A) passed in the light of Rule-46A(3) of the IT Rules, 1962. He prayed accordingly. 25. On the other hand, the Ld. AR of the assessee vehemently supported the orders

Divay Mohindru, Jalandhar vs. Income Tax Officer, Jalandhar

The appeal of the assessee is allowed

ITA 129/ASR/2025[2017-18]Status: DisposedITAT Amritsar08 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 129/Asr/2025 Assessment Year: 2017-18 Divay Mohindru, Prop. M/S Vs. Ito, Ward 3(1), Mahavir Abhushans, Deep Jalandhar. Market Juakhana Bazar Kalan, Jalandhar. [Pan:-Advpm1552D] (Appellant) (Respondent) Appellant By Sh. Asharay Sarna, Ca. Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 14.10.2025 Date Of Pronouncement 08.01.2026

Section 115BSection 143Section 143(3)Section 145(3)Section 250Section 69A

details along with ledger , and complete sets of books of accounts ( un audited ) , along with additional evidences, for which remand report was obtained under Rule 46A of the Rules 62. Further queries raised in course of remand were also responded along with more details and particulars as asked

Income Tax Officer, Pune vs. Sagar Construction Company, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1812/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Suhas Bora and Riya OswalFor Respondent: Shri S. Sadananda Singh, JCIT
Section 142(1)Section 143(1)Section 147Section 148Section 269SSection 37Section 68

lenders and TDS certificates / 15G forms for verification. The assessee filed an application for admission of additional evidences under Rule 46A before the Ld. CIT(A) / NFAC. The invocation of 6 CO No.43/PUN/2025 provisions of section 115BBE of the Act was also challenged before the Ld. CIT(A) / NFAC ... facts and in the circumstances of the case and in law, the Hon'ble CIT(A) erred in not complying with the provision of Rule 46A(3) of the IT Rules while admitting fresh evidence in the form of confirmation letter, PAN number, bank statement of lender along with

Muthukrishnan, Cuddalore vs. Income Tax Officer, Cuddalore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2615/CHNY/2025[2011-2012]Status: DisposedITAT Chennai08 Jan 2026AY 2011-2012

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 2615/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Shri Muthukrishnan, The Income Tax Officer, 74, Pillayar Koil Street, Vs. Ward 1, Sipcot, Cuddalore Cuddalore – 607 005. Pan: Avmpm 4855E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. R. Hemalatha, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 08.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 08.01.2026

For Appellant: Ms. R. Hemalatha, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 144Section 250

record. Before the FAA, the assessee has produced certain details and documents but failed to file the petition for admission of additional evidences under Rule 46A of the Income-tax Rules. Therefore, the FAA had dismissed the appeal of the assessee without considering the additional evidences filed before him. Moreover

Jainam Builders, Raipur vs. Income Tax Officer, Ward 1(2), Raipur

In the result, appeal of the assessee is allowed for statistical purposes

ITA 638/RPR/2025[2018-19]Status: HeardITAT Raipur07 Jan 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.638/Rpr/2025 "नधा"रण वष" / Assessment Year : 2018-19 Jainam Builders Rampuria Niwas, Gudhyari, Raipur-492 001 Pan: Aaffj0056L

For Appellant: Shri Praveen Khandelwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 142(1)

Appeals)/NFAC will not to be within the periphery of additional evidences and therefore, even without going in to the aspect of compliance regarding Rule 46A(3) of the IT Rules, 1962, since the assessee was prevented due to insufficient time to upload the submissions/documents before

ACIT., Circle-6(1), Hyderabad vs. Vk Warehousing Enterprises, Hyderabad

In the result, both the appeals filed by the assessee firm and

ITA 881/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18
For Appellant: Shri Rajesh Vaishnav, C.AFor Respondent: Shri P. Dhivahar, CIT-DR
Section 143(2)Section 144Section 234BSection 271(1)(b)Section 40Section 68Section 69Section 69CSection 801B

following grounds of appeal before us: "1. The Ld. CIT(A) erred in law in not granting opportunity to the Assessing Officer under Rule 46A to examine the additional evidence submitted by the assessee with regards to the issue of deduction claimed u/s. 801B ... observations, reject the aforesaid claim of the assessee company. 15. Coming to the grievance of the Revenue, we find that no specific violation of Rule 46A of the Income-tax Rules, 1962 has been demonstrated before us. However, we also observe that the CIT(A) has summarily accepted the claim

Vk Warehousing Enterprises, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

In the result, both the appeals filed by the assessee firm and the revenue are partly allowed for statistical purposes, in terms of our observations recorded hereinabove

ITA 737/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.737/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) M/S. V K Warehousing Enterprises, Dy. Commissioner Of Income Tax, Vs. Circle 6(1), Hyderabad. Hyderabad. Pan : Aakfv3288R (Appellant) (Respondent) आ.अपी.सं /Ita No.881/Hyd/2025 (िनधा"रण वष"/Assessment Year:2017-18) Dy. Commissioner Of Income Tax, M/S. V K Warehousing Enterprises, Circle 6(1), Hyderabad. Vs. Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Rajesh Vaishnav, C.A. राज" व "ारा/Revenue By: Shri P. Dhivahar, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026

For Appellant: Shri Rajesh Vaishnav, C.AFor Respondent: Shri P. Dhivahar, CIT-DR
Section 143(2)Section 144Section 234BSection 271(1)(b)Section 40Section 69Section 69CSection 801B

appeal before us: ITA Nos.737 & 881/Hyd/2025 3 “1. The Ld. CIT(A) erred in law in not granting opportunity to the Assessing Officer under Rule 46A to examine the additional evidence submitted by the assessee with regards to the issue of deduction claimed u/s. 801B ... claim of the assessee company. ITA Nos.737 & 881/Hyd/2025 9 15. Coming to the grievance of the Revenue, we find that no specific violation of Rule 46A of the Income-tax Rules, 1962 has been demonstrated before us. However, we also observe that the CIT(A) has summarily accepted the claim

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 Ltd, Dhanbad vs. ACIT Cir-1, Dhanbad

ITA 293/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, 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) (Α.Υ :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 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement Per Bench : आदेश / Order 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 1Section 143(3)Section 14ASection 32(2)

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