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

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

12 days in filing the appeal by the department and in support of which a condonation petition was filed. It was stated that the delay has occurred due to obtaining the administrative approvals from the competent authorities in the tax hierarchy , which took time and accordingly, the delay may be condoned. The ld. AR, on the other hand

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

bogus purchase,\nfictitious sale, false commission receipt, or unverifiable expense was\nidentified or quantified by the auditor. In the absence of such specific\nadverse findings, the assessee submitted that the AO was not\njustified in drawing sweeping conclusions solely on the basis of the\naudit report.\n2.1.4.3. The Id AR submitted that the Assessing Officer, while\nframing the assessment under

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

bogus purchase,\nfictitious sale, false commission receipt, or unverifiable expense was\nidentified or quantified by the auditor. In the absence of such specific\nadverse findings, the assessee submitted that the AO was not\njustified in drawing sweeping conclusions solely on the basis of the\naudit report.\n2.1.4.3. The Id AR submitted that the Assessing Officer, while\nframing the assessment under

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

12,75,394/-). It is clarified here that all deduction allowable under the provisions of sections 30 to 38 shall be deemed to have already been given full effect to and no further deduction under those sections shall be allowed. Further, assessee has received interest income of Rs.1,89,99,741/- and discount income of Rs.1,55,763/- during

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

12 months of the sale of the shares. Hence. these Appeals are dismissed. ii) CCIT Vs Nilesh Jain (HUF) 163 taxmann.com 229 (Madhya Pradesh), wherein it has been held that:- “Assessee purchased shares via private placement from a company that later amalgamated with another listed company on Bombay Stock Exchange - After amalgamation, share prices rose sharply due to speculative activities

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

12 months of the sale of the shares. Hence. these Appeals are dismissed. ii) CCIT Vs Nilesh Jain (HUF) 163 taxmann.com 229 (Madhya Pradesh), wherein it has been held that:- “Assessee purchased shares via private placement from a company that later amalgamated with another listed company on Bombay Stock Exchange - After amalgamation, share prices rose sharply due to speculative activities

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

12 months of the sale of the shares. Hence. these Appeals are dismissed. ii) CCIT Vs Nilesh Jain (HUF) 163 taxmann.com 229 (Madhya Pradesh), wherein it has been held that:- “Assessee purchased shares via private placement from a company that later amalgamated with another listed company on Bombay Stock Exchange - After amalgamation, share prices rose sharply due to speculative activities

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

12 months of the sale of the shares. Hence. these Appeals are dismissed. ii) CCIT Vs Nilesh Jain (HUF) 163 taxmann.com 229 (Madhya Pradesh), wherein it has been held that:- “Assessee purchased shares via private placement from a company that later amalgamated with another listed company on Bombay Stock Exchange - After amalgamation, share prices rose sharply due to speculative activities

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

12 months of the sale of the shares. Hence. these Appeals are dismissed. ii) CCIT Vs Nilesh Jain (HUF) 163 taxmann.com 229 (Madhya Pradesh), wherein it has been held that:- “Assessee purchased shares via private placement from a company that later amalgamated with another listed company on Bombay Stock Exchange - After amalgamation, share prices rose sharply due to speculative activities

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

12,41,180/- under the head “profit and gains from business or profession” and “income from other sources”. The case was selected for Complete Scrutiny through Computer Assisted Scrutiny Selection (CASS) to verify the issue on “High Risk Transactions.” Accordingly, notice u/s 143(2)/142(1) of the I.T. Act was issued and the same was served upon the assessee

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

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

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) &

12 or Principal Commissioner or Commissioner, in consequence of information in his possession, has reason to believe that- (a) any person to whom a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section

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) &

12 or Principal Commissioner or Commissioner, in consequence of information in his possession, has reason to believe that- (a) any person to whom a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section

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) &

12 or Principal Commissioner or Commissioner, in consequence of information in his possession, has reason to believe that- (a) any person to whom a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section

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) &

12 or Principal Commissioner or Commissioner, in consequence of information in his possession, has reason to believe that- (a) any person to whom a summons under sub-section (1) of section 37 of the Indian Income-tax Act, 1922 (11 of 1922), or under sub-section (1) of section 131 of this Act, or a notice under sub-section

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