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) &

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 (4) of section 22 of the Indian Income-tax Act, 1922, or under sub-section (1) of section 142 of this Act was issued to produce, or cause to be produced

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) &

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 (4) of section 22 of the Indian Income-tax Act, 1922, or under sub-section (1) of section 142 of this Act was issued to produce, or cause to be produced

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

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

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

bogus is unwarranted, unjustified misleading the facts. Since the sundry creditors amounting to 2,37,71,018.00 is not related to only for this Asstt. Yr. 2015-16. As because it includes 1,13, 20,437/- for earlier yrs. 3. That under the facts and circumstances of the case the Ld. CIT(A) failed to appreciate that as the appellant

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

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA 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

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA 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. PIYUSH & ASSOCIATES PRIVATE LIMITED, 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

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

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

37 Taxmann.com 7 (Mum) (Trib) the CIT accorded his sanction/approval by simply affixing "approved" at the bottom of the proposal prepared by A.O. It was held that such approval cannot be construed as sanction/approval u/s 151(1) of Income Tax Act, 1961. Accordingly, the reassessment proceedings were held to be bad- in-law.” 12. As discussed above, the reasons recorded

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

37 Taxmann.com 7 (Mum) (Trib) the CIT accorded his sanction/approval by simply affixing "approved" at the bottom of the proposal prepared by A.O. It was held that such approval cannot be construed as sanction/approval u/s 151(1) of Income Tax Act, 1961. Accordingly, the reassessment proceedings were held to be bad- in-law.” 12. As discussed above, the reasons recorded

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

37 Taxmann.com 7 (Mum) (Trib) the CIT accorded his sanction/approval by simply affixing "approved" at the bottom of the proposal prepared by A.O. It was held that such approval cannot be construed as sanction/approval u/s 151(1) of Income Tax Act, 1961. Accordingly, the reassessment proceedings were held to be bad- in-law.” 12. As discussed above, the reasons recorded

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

37 Taxmann.com 7 (Mum) (Trib) the CIT accorded his sanction/approval by simply affixing "approved" at the bottom of the proposal prepared by A.O. It was held that such approval cannot be construed as sanction/approval u/s 151(1) of Income Tax Act, 1961. Accordingly, the reassessment proceedings were held to be bad- in-law.” 12. As discussed above, the reasons recorded

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

37 Taxmann.com 7 (Mum) (Trib) the CIT accorded his sanction/approval by simply affixing "approved" at the bottom of the proposal prepared by A.O. It was held that such approval cannot be construed as sanction/approval u/s 151(1) of Income Tax Act, 1961. Accordingly, the reassessment proceedings were held to be bad- in-law.” 12. As discussed above, the reasons recorded