SEEMA SRIVASTAVA,PATNA vs. ITO,DC/AC-6, PATNA, PATNA

In the result, the appeal is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

TDS of Rs. 1,50,000/- u/s 194-IB of the Act. The Ld. AO issued a show cause notice dated 30/11/2019 in response to which the reply was filed by the assessee. As regards the exemption u/s 54/54F of the Act, the assessee had submitted purchase deed of only the new asset against which the deduction was claimed. Therefore

HARIHAR PRASAD,PATNA vs. ITO WARD 4 (4), PATNA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

50,000/- had been paid as compensation to the assessee after deducting TDS. The Assessing Officer (hereinafter ITA No.: 268/PAT/2023 Assessment Year: 2017-18 Harihar Prasad. referred to as the Ld. 'AO') issued notices under section

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S ASHA REALTY DEVELOPERS PVT LTD, MUZAFFARPUR

In the result, the appeal of the Revenue is dismissed

50,11,000\nvihar\nPhase-Il\nAsha\n100%\n14088\n14088\n100\n2,67,04,291\n33,37,68,000\n3,37,68,000\nPlaza\nS.G.\n97.37%\n19825\n14684\n74.07\n4,75,58,147\n3,74,24,102\n3,84,34,500\n10,10,398\nSmriti\nB.L.\n27.12%\n22355\n7641\n34.18

ARANYA CLEARERS,GAYA vs. ITO, WARD-3(1), GAYA

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

TDS as discussed above in para 4.3 Total assessed income Rs.61,50,858/- Total assessed income (rounded off u/s Rs.61,50,860/- 288A of the I.T. Act, 1961) Accordingly, the assessment order is passed u/s 144 r.w.s. 143(3) of the Income Tax Act, 1961 and the total income is assessed at Rs.61,50,860/-. Issue demand notice & challan, copy

RAVI LOCHAN SINGH,PATNA vs. ACIT, CIRCLE-5, PATNA

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

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

section 40(a)(ia) is attracted here also. Hence, It is my opinion that the assessee has claimed Rs. 18,91,877/- under the head of advertisement but he has not deducted TDS on the payments. Therefore, the AO proceeded to make disallowance of Rs. 18,91,877/- u/s 40(a) (ia) of the Income Tax Act, 1961 and added

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.

50,506: Disallowed under Chapter XVII-B for non-deduction of 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

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

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

50 lakhs as the ground of Rs. 8,26,,46,443/- being an unexplained expenditure for the relevant year shall not find merit in the legal context wherein the expenses stands immaterial if the net profit ratio has been maintained to be minimum 6% of the total turnover; and thus making the order under the section 263 illegal and invalid

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

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

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

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

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party

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 on such payment, therefore, these payments are not to be allowed as a deduction to the assessee under section 40(a)(ia) of the Income Tax Act. He further submitted that effort at the end of the assessee was to frustrate the ld. Assessing Officer for conducting proper inquiries in its accounts. The assessee kept on changing the stand

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S R.P.RAI ESTATE PVT LTD, PATNA

In the result, the appeal of the revenue is dismissed

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2017-18 Dcit, Circle-1, Muzaffarpur M/S. R.P. Rai Estate Pvt. Ltd. Vs 19, Goharua, Patliputra Colony, Patliputra, Patna- 800013. Pan: Aaccr 4972 P (Appellant) (Respondent) Present For: Appellant By : Shri Sushil Kumar Mishra, Jcit, Dr Respondent By : Shri Devesh Poddar, Advocate Date Of Hearing : 19.03.2024 Date Of Pronouncement : 03.04.2024 O R D E R Per Sonjoy Sarma, Jm: This Appeal Of The Revenue For The Assessment Year 2017-18 Is Directed Against The Order Dated 29.06.2020 Passed By The Ld. Commissioner Of Income-Tax (Appeal), Patna [Hereinafter Referred To As ‘The Ld. Cit(A)’].

TDS” followed by notices issued u/s 143(2) & 142(1) of the Act. In response to notices, the assessee has appeared time to time before the AO and furnished copy of audit report of business activities, bank statements, books of account, details of sundry creditors and payment certificate and a copy of 26AS statement. On examination of the various documents

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

TDS. 10. For that the ld. Commissioner of Income Tax (Appeal) as well as the Ld. assessing officer has erred in disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points