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) &

purchased property, the property is in Jasola but he does not remember address and he does not know whether registry has been done or not. 8. That the Ld. CIT(A) has wrongly equated the evidentiary value of the case diary of the police authority under the IPC with that of proceeding under Income Tax Act 1961. 9. That

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) &

purchased property, the property is in Jasola but he does not remember address and he does not know whether registry has been done or not. 8. That the Ld. CIT(A) has wrongly equated the evidentiary value of the case diary of the police authority under the IPC with that of proceeding under Income Tax Act 1961. 9. That

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

143(3) instead of Section 144, which also makes the assessment erroneous. It may be noted that in case of Amhara Constructions Pvt. Ltd., Patna which is also engaged in the business of government contracts involving construction and maintenance of roads, culverts, footpaths etc. has declared profits of 10% or more on 6 Assessment Year: 2018-2019 BBCPL- SKPL

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

143(3) instead of Section 144, which also makes the assessment erroneous. It may be noted that in case of Amhara Constructions Pvt. Ltd.. Patna which is also engaged in the business of government contracts involving construction and maintenance of roads, culverts, footpaths etc. has declared profits of 10% or more on a turnover of about Rs. 100 crores

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

143(3) instead of Section 144, which also makes the assessment erroneous. It may be noted that in case of Amhara Constructions Pvt. Ltd., Patna which is also engaged in the business of government contracts involving construction and maintenance of roads, culverts, footpaths etc. has declared profits of 10% or more on a turnover of about Rs. 100 crores

RAJ CONSTRUCTION,KATIHAR vs. ACIT, CIRCLE-1(1), BHAGALPUR

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

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am Asst. Commissioner Of Income Tax, Raj Construction Circle – 1(1), C/O Mahadev Ghosh, Bhagalpur, Advocate Vs. Bf-199, Salt Lake City, R.N. Plaza, R.B.S.S Kolkata-700064 Sahay Road, Bhagalpur, Bihar- 812001 (Appellant) (Respondent) Pan No. Aajfr6306F Assessee By : Shri Mahadev Ghosh, Ar Revenue By : Shri Ashwani Kumar, Dr Date Of Hearing: 20.08.2024 Date Of Pronouncement: 29.08.2024

Section 144/ 143(3) of the Income-tax Act, 1961 (the Act) dated 14th December, 2017. 02. Registry is informed that the appeal is time barred for 5 days. Application for condonation of delay has been filed. The delay in filing of appeal is attributable to the person Raj Construction; A.Y. 2015-16 looking after the appellate work. An affidavit

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

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

143(1) of the Income Tax Act. The ld. Assessing Officer thereafter observed that he has received an information from Investigation Wing that the assessee had obtained bogus accommodation entry in the nature of bogus unsecured loan. According to him, this loan was obtained by the assessee in F.Y. 2014-15 relating to A.Y. 2015-16. He recorded the reasons

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

143(3) of the Act dated 30.12.2016. 2.2. In the appellate proceedings, the learned CIT (A) allowed the appeal of the assessee by observing and holding as under:- “I have carefully considered the findings of the AO in the assessment order, submission of the appellant, Remand report of the AO and the comments of the appellant on the remand report

YASHWANT SINGH,PATNA vs. DCIT, PATNA

In the result, the appeals of the assessee ITA Nos

purchased the agricultural produce from the\nassessee. However, the Assessing Officer was not satisfied with the aforesaid\nstatement given by Shri Ram Prakash Rai and also noted that the said\nstatement was given by Shri Ram Prakash Rai at the instance of the assessee.\nThe Assessing Officer concluded that the assessee had failed to establish that\nthe aforesaid income shown

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

143(3) for A.Y.2016-2017, making additions in respective appeals. The Assessing Officer also for all the three assessment years under consideration has stated that the assessee has concealed the income, therefore, initiated the proceedings u/s.271(1)(c) of the Act imposing penalties as mentioned hereinabove. The assessee preferred appeals before the Id. CIT(A), the Id. CIT(A) reduced

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

143(3) for A.Y.2016-2017, making additions in respective appeals. The Assessing Officer also for all the three assessment years under consideration has stated that the assessee has concealed the income, therefore, initiated the proceedings u/s.271(1)(c) of the Act imposing penalties as mentioned hereinabove. The assessee preferred appeals before the Id. CIT(A), the Id. CIT(A) reduced

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

143(3) for A.Y.2016-2017, making additions in respective appeals. The Assessing Officer also for all the three assessment years under consideration has stated that the assessee has concealed the income, therefore, initiated the proceedings u/s.271(1)(c) of the Act imposing penalties as mentioned hereinabove. The assessee preferred appeals before the Id. CIT(A), the Id. CIT(A) reduced

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

143(2)/142(1) of the I.T. Act was issued and the same was served upon the assessee on his registered mail through ITBA Portal as well as by speed post. There was no compliance to the notices issued. Thereafter, show cause notice was issued to the assessee for requiring him to furnish the information/ documents/accounts details of cash deposited

SANJAY KUMAR SHAH,ARARIA vs. ACIT, CIRCLE-3, PURNIA

In the result, appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2014-15

143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 23.12.2016 for AY 2014-15. 2. Assessee has raised the following grounds of appeal: 1. For that on the fad & circumstances of the case, the order of dismissal of the learned Commissioner of Income Tax (Appeal), Bhagalpur is bad in law & fact and also totally

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.

143(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

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