I.T.O. vs. M/S KUMAR CONSTRUCLTION,

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

TDS has not been deducted on aforementioned amount. ” 15. As per Sec. 40(a)(ia), if any rent is liable for tax deduction u/s 1941 and tax has not been deducted, the expense is not allowable. Therefore, Rs. 1,43,10,424/- is disallowed u/s 40(a)(ia) and added back to the income of the assessee. It is pertinent

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT (CENTRAL), PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

TDS deducted thereon, register marked as NPT-02, details about cash receipt from different persons referred in seized material NPT-02. Reference also made to seized document BKC-03, MCT-10, MCT-13, NPT-01. Ld. Pr. CIT also asked the assessee to explain about the page wise description of receipt and payment written in the seized material marked

SRIRAM ENTERPRISES,PATNA vs. PCIT (CENTRAL), PATNA

In the result, the appeal of the assessee is allowed

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 76/Pat/2023 Assessment Year: 2018-2019 Sriram Enterprises,………………………..........Appellant C/O. Nirmal & Associates, Nepali Kothi, Opposite Gasoline Petrol Pump, Boring Road, Patna-800001 [Pan:Aarfs8853J] -Vs.- Principal Commissioner Of Income Tax (Central), Patna,…………………………………..……………..Respondent, Bihar-800001 Appearances By: Shri Nishant Maitin, C.A., Appeared On Behalf Of The Assessee Md. A.H. Chowdhary, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : 5Th March, 2024 Date Of Pronouncing The Order: May 8Th, 2024 O R D E R

1) of the Act to which necessary submissions/details/information/documents were furnished electronically and hard-copy was also placed. The ld. Assessing Officer after examining these details and after calling for more information and considering the Net Profit rate trend, which is on higher side accepted the returned income. Thereafter ld. Pr. CIT 3 Assessment Year: 2018-2019 Sriram Enterprises called

ASHISH RANJAN,DARBHANGA vs. INCOME TAX OFFICER, DARBHANGA

In the result, the appeal of the assessee is allowed

43,570/- was created on account of\nmismatch of Tax Deducted at source.\n2.2. The appeal of the assessee was dismissed by the Id. CIT (A) by\nobserving and holding as under:-\n“8. The Ground No. 2, 3, 5 and 6 raised by the appellant are related to the same issue\ni.e. denial of TDS amounting to Rs.8

PUNAM HISARIA,SITAMARHI vs. DC/AC, CIRCLE-03, DARBH, DARBH

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

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No.80/Pat/2023 Assessment Year: 2017-18 Punam Hisaria ………. Appellant (Pan: Abupa3945R)

Section 40(a)(ia) should not be invoked for payment without TDS as per several decisions of different ITAT referred during the course of appellate proceedings. 4. Ground 4. For that during the remand proceedings Ld. A.O. was provided complete books of accounts, Ledger copy of freight copy of declaration of other truck owners whose freights amount to Rs.1

PIONEER EDUCATION SOCIETY,HARYANA vs. ITO, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 405/Pat/2024 Assessment Year: 2016-2017 Pioneer Education Society,……….…….....……Appellant C-310/311, Unitech Business Zone Nirvana Country, South City-Ii, Sector-50, Haryana, Pin Code No.122018 [Pan:Aadap0174C] -Vs.- Income Tax Officer,……………………………….Respondent Ward-1(1), Patna, Lok Nayak Jai Prakash Bhawan, New Dak Bunglow, Patna-800001, Bihar Appearances By: Shri Yatin Sharma, Advocate, Appeared On Behalf Of The Assessee Rinku Singh, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 21, 2025 Date Of Pronouncing The Order: April 24, 2025 O R D E R

1)(b) was issued to the assessee on 30.11.2018 requiring compliance on 05.12.2018. Again, letter under section 133(6) was issued to the Branch Manager, Axis Bank, Valachery Branch, Chennai seeking copy of all bank statements of the assessee. Copy of Bank statements received from the Branch and from where it was noticed that the assessee society had undergone various

UTTAR BIHAR GRAMIN BANK,MUZAFFARPUR vs. DC/AC CIRCLE-2, MUZAFFARPUR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.186/Pat/2025 Assessment Year: 2016-17 Uttar Bihar Gramin Bank……….....…..…………………....Appellant Sharma Complex, Ramna Kalambagh Chowk, Muzaffarpur, Bihar – 842002. [Pan: Aaaju0238J] Vs. Dc/Ac, Circle-2, Muzaffarpur.……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 22, 2025 Date Of Pronouncing The Order : July 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Has Been Filed By The Assessee Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Patna ["Cit(A)"] For The Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Declaring A Total Loss Of Rs.47,24,77,982. The Case Was Selected For Scrutiny Under Compulsory Manual Selection Criteria During The Financial Year 2017-18. Accordingly, Statutory Notices Under Sections 143(2) & 142(1) Of The Income-Tax Act, 1961 ("The Act") Were Issued & Duly Served Upon The Assessee. In Response, The Assessee Appeared & Made Certain Submissions. However, The Assessing Officer Made The Following Additions/Disallowances: Rs.16,84,20,016: Provision For Npa.

TDS. Rs.84,57,75,179: Disallowed claim of interest. Rs.5,08,291: Disallowed expenditure under the head "Food & Beverages" to staff. Rs.28,17,546: Disallowed contribution towards Provident Fund under section 36(1)(va) as not deposited before the due date. After the above disallowances, the total income of the assessee was assessed at Rs.1,43

CHINMASTIKA SIDHARTHA(JV),PATNA vs. CIT(A), PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz)

1) of the Act and selected for scrutiny through CASS. Accordingly notice under section 143(2) of the Act was issued by the ld. Assessing Officer on 29.07.2016 and served upon the assessee. In response to the notice, ld. Advocate on behalf of assessee produced details and documents with written submission. On perusal of the return of income

NILU KUMARI,SARAN vs. ASSESSMENT UNIT, INCOME TX DPTT., DELHI

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

Bench: Shri George Mathan & Shri Rakesh Mishra

1,71,43,650. 4. For that the Ld. AO has assumed that all the credit appearing in the Bank account are in the nature of unexplained money under section 69A. The appellant in its written submission bank statement, dated 09/11/2022 and 19/12/2022 has submitted the copies of form 26AS along with the chart showing details of Income earned

SOCIETY FOR ADVANCEMENT OF VILLAGE ECONOMY,GAYA vs. ACIT(EXEMPTION) CIRCLE, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

TDS was not deducted on payments to CSP, a sum of ₹71,79,910/- paid to CSP agents was disallowed u/s 40(a)(ia) of the Act. Thus, the excess on income over expenditure was considered and the disallowance u/s 40(a)(ia) of the Act was also considered and the total income has been assessed at ₹1

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

In the result, the appeal filed by the assessee is allowed

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

1, the details tax audit report and Financials for FY 2012-13, relevant to Ay 2013-14 are hereby attached for our honours kind attentions and records. 2. With respect to point 2 and 3, the company , during the relevant year, was only maintaining account with HDFC bank, the statement of which is hereby annexed for the period