ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S AL-KARIM EDUCATIONAL TRUST, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

sections of Indian Penal Code. A case under Prevention of Corruption Act. A case under Bihar Examination Control Act and a case under Arms Act filed against Md. AA Karim. This above fact was disclosed by the Income Tax Department in their Appraisal report without any information about filing of any case against AI- Karim Educational Trust. 1

ACIT, CENTRAL CIRCLE-2, PATNA vs. NUZHAT NASREEN, L/H AHMAD ASHFAQUEKARIM OF NUZHAT NASREEN, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

sections of Indian Penal Code. A case under Prevention of Corruption Act. A case under Bihar Examination Control Act and a case under Arms Act filed against Md. AA Karim. This above fact was disclosed by the Income Tax Department in their Appraisal report without any information about filing of any case against AI- Karim Educational Trust. 1

RAJESH KUMAR AGARWAL HUF,MUZAFFARPUR vs. AC/DCIT CENT CIR MZF, MUZAFFARPUR

In the result, the appeals of the revenue as well as that of the\nassessee are dismissed

1) and again in response to notice under section 148 on\n13.04.2024.We note that the books of accounts comprising the cash\nbook, bank book, journal, general ledger, party-wise purchase and\nsales registers, copies of sales invoices, purchase bills, and bank\nstatements, were duly produced during the course of assessment\nproceedings and were also made available to the Special Auditor

DY. COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), MUZAFFARPUR, MUZAFFARPUR vs. RAJESH KUMAR AGARWAL HUF, MUZAFFARPUR

In the result, the appeals of the revenue as well as that of the\nassessee are dismissed

1) and again in response to notice under section 148 on\n13.04.2024.We note that the books of accounts comprising the cash\nbook, bank book, journal, general ledger, party-wise purchase and\nsales registers, copies of sales invoices, purchase bills, and bank\nstatements, were duly produced during the course of assessment\nproceedings and were also made available to the Special Auditor

M/S PSP TRADING PVT LTD,PATNA vs. ITO, WARD- 2 (1), PATNA

In the result, the appeal of the assessee is allowed

bogus company to be unfounded, especially since the supplier's manufacturing unit was in Jharkhand, but the notice was served on a Kolkata address where the company could not be found.", "result": "Allowed", "sections": [ "37", "139", "147", "148", "133(6)", "143(1)", "147/1448" ], "issues": "Whether the purchases

BALKRISHNA BHALOTIA CONSTRUCTION PRIVATE LIMITED,JAMUI vs. PCIT CENTRAL, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

purchases and allowability of the same under the provisions of the Income Tax Act. The chances of such purchases/expenses being bogus is high and the amount may be substantially higher than the credit balances admitted by the assessee to be nonexistent and offered for taxation. This lack of enquiry makes the assessment order erroneous and prejudicial to the interest

BBCPL-SKPL (JV),JAMUI vs. PCIT CENTRAL, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

purchases and allowability of the same under the provisions of the Income Tax Act. The chances of such purchases/expenses being bogus is high and the amount may be substantially higher than the credit balances admitted by the assessee to be non-existent and offered for taxation. This lack of enquiry makes the assessment order erroneous and prejudicial to the interest

BBCPL-RCPL (JV),JAMUI vs. PCIT CENTRAL, PATNA, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

purchases and allowability of the same under the provisions of the Income Tax Act. The chances of such purchases/expenses being bogus is high, considering the fact that in related sister concern of M/s Balkrishana Bhalotia Construction Private Limited (BBCPL) and joint venture partner, non existing creditors’ balances of more than Rs.9 crores were offered by the assessee, and has been

ITO, WARD-2(1), BEGUSARAI, BEGUSARAI vs. MANISH KUMAR MOTANI, KHAGARIA, BIHAR

In the result, the appeal of the Revenue and CO of the Assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Appellant) (Respondent) Pan No. Ajjpm4263D Co No. 02/Pat/2025 (Arising In Ita No. 442/Pat/2024 For A.Y. 2017-18) Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Applicant) (Respondent) Assessee By : S/Shri A.K. Rastogi, S.K. Duta, Ars Revenue By : Shri A.H. Chowdhary, Dr Date Of Hearing: 24.11.2025 Date Of Pronouncement: 26.02.2026

bogus claims, he disallowed said expenditure of Rs. 2.08 crores invoking section 40A(3) Commissioner was of opinion that in essence Assessing Officer had disputed expenditure claimed by assessee and indirectly applied section 37 He was of opinion that not entire expenditure which was under cloud but profit element embedded therein should be brought to tax and, thus, limited disallowance

DY. COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), MUZAFFARPUR vs. RAJESH KUMAR AGARWAL HUF, MUZAFFARPUR

In the result, the appeals of the revenue as well as that of the\nassessee are dismissed

1) and again in response to notice under section 148 on\n13.04.2024.We note that the books of accounts comprising the cash\nbook, bank book, journal, general ledger, party-wise purchase and\nsales registers, copies of sales invoices, purchase bills, and bank\nstatements, were duly produced during the course of assessment\nproceedings and were also made available to the Special Auditor

SHREE MANGALAM ALUMINIUM,PATNA vs. DC/ACIT, CENTRAL CIRCLE-3, PATNA

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 271(1)(c) in a case where the income has been determined by the Assessing Officer on estimate basis. (5) For that Ld. CIT(A) has erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases

SHREE MANGALAM ALUMINIUM,PATNA vs. DC/ACIT, CENTRAL CIRCLE-3, PATNA

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 271(1)(c) in a case where the income has been determined by the Assessing Officer on estimate basis. (5) For that Ld. CIT(A) has erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases

SHREE MANGALAM ALUMINIUM,PATNA vs. DC/ACIT, CENTRAL CIRCLE-3, PATNA

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 271(1)(c) in a case where the income has been determined by the Assessing Officer on estimate basis. (5) For that Ld. CIT(A) has erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases

SHANKAR CONSTRUCTION,PANCHGACHIA vs. ITO, WARD-3(1), PURNEA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumari.T.A. No. 565/Pat/2024 Assessment Year: 2016-2017 Shankar Construction,………………..…….……Appellant Panchgachia, Panchgachia-852124, Bihar [Pan:Abofs0800R] -Vs.- Income Tax Officer,………………….……..……Respondent Ward-3(1), Purnea, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate, Appeared On Behalf Of The Assessee Shri Ashok Kumar, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: October 22, 2024 Date Of Pronouncing The Order: November 18, 2024 O R D E R

bogus Kolkata based shell companies." That reason recorded above like “………….Thus, the loan taken by the assessee ie. M/s Shanker Construction is to be treated as unexplained cash credit in the books of the assessee under the provision of section 68 of the Act. In this regard, enquiry was carried out on ITBA, e-filling portal and ITD database

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. RAJESH KUMAR AGARWAL HUF, MUZAFFARPUR

In the result, the appeals of the revenue as well as that of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

1) and again in response to notice under section 148 on 13.04.2024.We note that the books of accounts comprising the cash book, bank book, journal, general ledger, party-wise purchase and sales registers, copies of sales invoices, purchase bills, and bank statements, were duly produced during the course of assessment proceedings and were also made available to the Special Auditor

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. RAJESH KUMAR AGARWAL HUF, MUZAFFARPUR

In the result, the appeals of the revenue as well as that of the assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

1) and again in response to notice under section 148 on 13.04.2024.We note that the books of accounts comprising the cash book, bank book, journal, general ledger, party-wise purchase and sales registers, copies of sales invoices, purchase bills, and bank statements, were duly produced during the course of assessment proceedings and were also made available to the Special Auditor

ACIT, CIRCLE-2, PATNA vs. SHREE NANAK FERRO ALLOYS PVT LTD, JAMSHEDPUR

In the result, the appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Shree Nanak Ferro Alloys Pvt. Ltd. Acit, Circle-2 Room No.205, 2Nd Floor, Avrtar Acit, Circle-2, Patna, Bihar Vs. Building, Bisturpur, Jamshedpur, Jharkhand (Appellant) (Respondent) Pan No. Aaics1706N Assessee By : S/Shri A.K. Rastogi Rakesh Kumar, Ar Revenue By : Shri Md Ah Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 09.12.2025

Section 148 of the Act on 04.11.2015, after the learned Assessing Officer received information from Director of Income Tax (I & CI) that appellant had received bogus entries of cash from hawala operators. The said notice was complied with by the assessee by stating that original return filed may kindly be treated as return in response to the said notice

SANTOSH KUMAR KESHRI,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 226/Pat/2024 Assessment Year: 2017-2018 Santosh Kumar Keshri,………..…….…………Appellant Shop No. 3, Jaiswal Market, Sabji Mandi, Mithapur-800001, Bihar [Pan:Asapk1127E] -Vs.- Assistant Commissioner Of Income Tax,...Respondent Dc/Ac Circle-6, Patna-800001, Bihar Appearances By: Shri Supriya Sharma, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 19, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

bogus Sundry Creditors to the total Income of the assessee under section 68 of the Act and the same figure of addition was upheld by Commissioner (Appeals). The Assessee had provided the list of Sundry Creditors to the Ld. A.O. and the bank statements for the F.Y. 2016-17 and 2017-18 for verification of genuineness of the transactions along