ACIT CENTRAL CIRCLE-2, PATNA vs. AHMAD ASHFAQUE KARIM, 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

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

11\n139(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

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

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-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

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

11\n139(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

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

11 Shankar Construction It was also proved beyond doubt that the assessee company's source of found of making huge loans is also from bogus Kolkata based shell companies. Hence, the loan received by M/s Shankar construction may be added under the provision of section 68 of the Act as the assessee has availed accommodation unsecured loan from

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 is against the deletion of addition of ₹7,33,57,570/- by ld. CIT(A) as made by the AO by treating income as undisclosed business income from sale of Raj Niwas Pan Masala ITA Nos. 289 to 291, 301 & 302/Pat/2025 Rajesh Kumar Agarwal, HUF; A.Ys.2020-21, 2022-23, 2023-24, 2021-22 2.1.1. The facts in brief

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 is against the deletion of addition of ₹7,33,57,570/- by ld. CIT(A) as made by the AO by treating income as undisclosed business income from sale of Raj Niwas Pan Masala ITA Nos. 289 to 291, 301 & 302/Pat/2025 Rajesh Kumar Agarwal, HUF; A.Ys.2020-21, 2022-23, 2023-24, 2021-22 2.1.1. The facts in brief

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

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

1:10, and as such, the assessee became beneficiary of 60000 shares, which were sold during the assessment year under consideration i.e. AY 2015-16. The Ld. Counsel for the assessee has further contended that when the shares in question were purchased during the AY 2013-14 through the IPO and the same were showing in the Demat account

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

1:10, and as such, the assessee became beneficiary of 60000 shares, which were sold during the assessment year under consideration i.e. AY 2015-16. The Ld. Counsel for the assessee has further contended that when the shares in question were purchased during the AY 2013-14 through the IPO and the same were showing in the Demat account

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

1:10, and as such, the assessee became beneficiary of 60000 shares, which were sold during the assessment year under consideration i.e. AY 2015-16. The Ld. Counsel for the assessee has further contended that when the shares in question were purchased during the AY 2013-14 through the IPO and the same were showing in the Demat account

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

1:10, and as such, the assessee became beneficiary of 60000 shares, which were sold during the assessment year under consideration i.e. AY 2015-16. The Ld. Counsel for the assessee has further contended that when the shares in question were purchased during the AY 2013-14 through the IPO and the same were showing in the Demat account

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

1:10, and as such, the assessee became beneficiary of 60000 shares, which were sold during the assessment year under consideration i.e. AY 2015-16. The Ld. Counsel for the assessee has further contended that when the shares in question were purchased during the AY 2013-14 through the IPO and the same were showing in the Demat account

PIYUSH & ASSOCIATES PRIVATE LIMITED,PATNA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

ACIT, CENTRAL CIRCLE-1, PATNA vs. PROMINENT FINANCIAL ADVISORY PVT LTD, KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished