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

purchase expenditure by raising bogus claims, he disallowed said expenditure of Rs. 2.08 crores invoking section 40A(3) Commissioner was of opinion

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

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

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

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

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

3,31,18,000/­ (approx) throughout the year is not for any business exigencies for purchasing a huge volume of agricultural product from agriculturists. As a result, the disallowance of' 16,55,900/­ from out of total expenses claim remain totally arbitrary without any proof of bogus payment and the payments are not for the exceptional & unavoidable circumstances and also

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

bogus commission income. 3. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A)-3, Patna erred in not considering the observation of the Special Auditor, in which he reported that no conclusive evidence regarding exempted sale, exempted purchase, commission income and expenses shown in the profit and loss account

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

bogus commission income. 3. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A)-3, Patna erred in not considering the observation of the Special Auditor, in which he reported that no conclusive evidence regarding exempted sale, exempted purchase, commission income and expenses shown in the profit and loss account

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. 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) &

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. 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) &

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

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

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

3, 22,525 equity shares of a face value of Rs. 2 each and hold 0.92% share holding in DB. Further, it was also observed that M/s New KMS Finance Pvt. Ltd had made huge investments in different companies and source of these investments was the securities premium of Rs. 72, 00, 02,200/- received from various Kolkata based companies

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

3) r.w.s.147 on 30.12.2016 determining total income at Rs.4,34,69,370/-. As stated earlier the AO was in receipt of information from the Director of Income-tax (I&CI), Bhopal. In this report, ITO (I&Cl) investigated huge cash deposits made in name of Anand Agrawal, Ashish Agrawal and Amit Purohit. These persons had made huge deposits in cash

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

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

3) For that the Ld. CIT(A) has erred in invoking provisions of Section 106 of the Evidence Act whereas the fact remains that the fiscal law is guided by pre-ponderance of probability and the provisions of Evidence Act are strictly not applicable. . (4) For that the Ld. CIT(A) has erred in invoking Explanation 5A to Section

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

3) For that the Ld. CIT(A) has erred in invoking provisions of Section 106 of the Evidence Act whereas the fact remains that the fiscal law is guided by pre-ponderance of probability and the provisions of Evidence Act are strictly not applicable. . (4) For that the Ld. CIT(A) has erred in invoking Explanation 5A to Section

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

3) For that the Ld. CIT(A) has erred in invoking provisions of Section 106 of the Evidence Act whereas the fact remains that the fiscal law is guided by pre-ponderance of probability and the provisions of Evidence Act are strictly not applicable. . (4) For that the Ld. CIT(A) has erred in invoking Explanation 5A to Section