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) &

bogus claim for exemption U/s. 10(23C) of the Income Tax Act, 1961. A letter for cancellation of registration for exemption has been written by the concerned Assessing Officer, Central Circle - 2, Patna to the Principle Chief Commissioner of Income Tax, Bihar & Jharkhand (copy enclosed for kind reference).” This part of the remand report relating to the AI-Karim Educational

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) &

bogus claim for exemption U/s. 10(23C) of the Income Tax Act, 1961. A letter for cancellation of registration for exemption has been written by the concerned Assessing Officer, Central Circle - 2, Patna to the Principle Chief Commissioner of Income Tax, Bihar & Jharkhand (copy enclosed for kind reference).” This part of the remand report relating to the AI-Karim Educational

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 thus, needs no separate adjudication.\nWe have upheld the order of Id. CIT(A). The grounds no. 3 and 4 are\ndismissed.\n2.4. The ground no. 5 is consequential and general in nature and requires\nno adjudication.\n2.5. The ground no. 6 is again procedural and requires no adjudication.\nITA Nos.290, 291, 301/PAT/2025\n3.\nThe issues raised

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 commission income, also deleted by the CIT(A).", "held": "The Tribunal noted that the assessee's food grain business turnover was fully disclosed and supported by documentation, and that the AO's approach of treating sales as non-genuine while accepting purchases was inconsistent. Regarding commission income, it was found to be fully disclosed, accounted for, and supported

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

139(1), in which total income disclosed was Rs.122868330/-, including interest income of Rs.18999741/-. This interest income pertained to the fixed deposit of the assessee company which was not related to the business activity and hence assessable under the head ‘income from other sources’. The Assessing Officer determined business profit @8% out of contractual receipts of Rs.1521275394/-, amounting to Rs.121702032

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

139(1), in which total income disclosed was Rs.15478192/- including Rs.10000000/- of income offered to tax, and interest income of Rs.1944075/-. This interest income pertained to the fixed deposits of the assessee company, which was not related to the business activity and hence assessable under the head ‘income from other sources’. The Assessing Officer determined business profit

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

139(1), in which total income disclosed was Rs.8906375/-. Thsr Assessing Officer determined business profit @8% out of contractual receipts of Rs. 124803177/-, amounting to Rs.9984,254/- which is only marginally higher than the net profit declared by the assessee. Interest income of Rs.2509727/- has also been assessed. Books of accounts of the assessee has been rejected

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 thus, needs no separate adjudication.\nWe have upheld the order of Id. CIT(A). The grounds no. 3 and 4 are\ndismissed.\n2.4. The ground no. 5 is consequential and general in nature and requires\nno adjudication.\n2.5. The ground no. 6 is again procedural and requires no adjudication.\nPage | 18\nITA Nos.290, 291, 301/PAT/2025\nAys

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

139(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

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

139(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

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

139 for the assessment year to the Income-tax Officer, or (b) to disclose fully and truly material facts necessary for his assessment for that year. Both these conditions must coexist in order to confer jurisdiction on the Income-tax Officer. It is also imperative for the Income-tax Officer to record his reason of before initiating proceedings as required

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

139(1) of the Act, declaring the total income of ₹18,41,971/-. The case of the assessee was reopened under Section 147 of the Act by issuing notice under Section 148 of the Act on 04.11.2015, which was not complied with by the assessee. Again, reminder dated 08.12.2015 was given, which was complied with by submitting a letter dated

SANGEETA GOEL,PATNA vs. CCIT, NFAC, PATNA

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 211/Pat/2024 Assessment Year: 2013-14 Sangeeta Goel Chief Commissioner Of Income-Tax/Nfac 506, Santosha Complex Vs Fraser Road Bander Bagicha Patna - 800001 [Pan: Acbpg0887A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.K. Tulsiyan, Advocate Revenue By : Shri Sushil Kumar Mishra, Jcit D/R सुनवाई क" तारीख/Date Of Hearing : 06/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 12/04/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”) Dt. 30/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. A. That The Initiation Of Proceeding U/S 147 R.W.S 148 Of The It Act, 1961 Based On Alleged Information Of Bogus Trade Amounting To Rs. 35,09,213/- In The Shares & Securities Of M/S Ayaan Commercial Pvt Ltd Being Bereft Of Fact & Assessee Having Not Carried On Any Such Transaction, The Assumption Of Jurisdiction U/S 147 Of The It Act, 1961 Is Bad In Law. B. That The Ld. A.O. Having Rejected The Objection Of The Assessee Although These Facts Are Brought On Record His Action In Doing So Is Bad In Law. C. That The Reopening U/S 147 Was Based On Mere Suspicion & Surmises, The Proceeding U/S 147 R.W.S. 148 Of The It Act, 1961 Is Bad In Law.

1) of the Act on 26/03/2015, accepting the returned income. Thereafter, notice dt. 31/03/2021 was issued u/s 148 of the Act asking the assessee to furnish the return of income to which necessary compliance was made and the assessee submitted return on 30/04/2021. The assessee asked for the reasons recorded for initiating proceedings