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) &

41,00,000/- made by the A.O. on the basis of case diary maintained by the police authorities, copy of which was submitted to the Income Tax Department on 27.03.2014. In the case diary contents of three diaries seized by police authorities from Ahmed Ashfaque Karim are mentioned and discussed in a very detailed manner. Case diary maintained

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) &

41,00,000/- made by the A.O. on the basis of case diary maintained by the police authorities, copy of which was submitted to the Income Tax Department on 27.03.2014. In the case diary contents of three diaries seized by police authorities from Ahmed Ashfaque Karim are mentioned and discussed in a very detailed manner. Case diary maintained

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2010-2011 Manish Finlease Pvt Ltd., Vs. Ito, Ward 2(1), Patna Chandi House Exhibition Road, Patna Pan/Gir No.Aaccm 6252 B (Appellant) .. ( Respondent) Assessee By : Shri A.K.Rastogi & Rakesh Kumar, Ars Revenue By : Shri Indrajeet Singh, Dr Date Of Hearing : 20/06/ 2019 Date Of Pronouncement : 09/08/ 2019 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-1, Patna Dated 27.9.2018 For The Assessment Year 2010-2011. 2. The Appeal Filed By The Assessee Is Delayed By 51 Days. The Assessee Has Filed Application For Condonation Of Delay Stating The Reasons For Not Filing The Appeal In Time Before The Tribunal. After Hearing The Submissions Of The Parties, We Are Satisfied That The Assessee Had A Bonafide Reason For Not Filing The Appeal In Time. Therefore, We Condone The Delay & Proceed To Decide The Appeal Of The Assessee On Merits.

purchase, salary, audit fees, printing and stationery, preliminary expenses, w/off, general expenses and back charges. The earnings per share shown in the notes of the account at page no.19 of the paper book is 0.09 & 0.04 for the financial year 2008-2009 & 2009-2010 respectively, the source thatthere is a no creditworthiness. We further noticed that there are huge reserve

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

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

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 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

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

41 ITR 191 (SC) and Narayanappa -vs.- Commissioner of Income Tax [1967] 63 ITR 219 (SC) while dealing with corresponding provisions of the Indian Income Tax Act, 1922). 9………………… 10………………. 11. As staled earlier, the reasons for the formation of the belief must have a rational connection with or relevant bearing on the formation of the belief. Rational connection postulates

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

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

SUDHIR KUMAR,PATNA vs. I.T.O., PATNA

In the result, the appeal of assessee is partly allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Girish Agrawalassessment Year: 2010-11 Shri Sudhir Kumar, Income-Tax Officer, Ward-6(1), Vs. Patna. Patna. (Pan: Amlpk4871E) (Appellant) (Respondent) Present For: Appellant By : Shri K. M. Mishra, Advocate Respondent By : Shri Sanjay Mukherjee, Cit(Dr) Date Of Hearing : 16.03.2022 Date Of Pronouncement : 26.05.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Dhanbad, Camp Office At Patna Appeal No. 71/Cit(A)-Ii/13-14 Dated 25.02.2014 For A.Y. 2010-11 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Ito, Ward-6(1), Patna, Dated 26.03.2013. 2. Brief Facts Of The Case Are That Assessee Had Filed Return Of Income On 18.10.2010 Reporting Total Income Of Rs.3,01,260/-. In The Course Of Assessment Proceedings, The Ld. Ao Sought Details On Various Aspects Of The Income Reported By The Assessee & Completed The Assessment By Making The Additions As Under: “Total Income As Per Return Rs. 3,01,260/- Add: As Discussed In Para D Rs. 3,42,708/- Add: As Discussed In Para E Rs. 14,03,744/- Add: As Discussed In Para F Rs. 58,92,354/- Total Income Rs. 89,40,066/-“

section 44AD and by stating so the representative of the assessee has argued that the total income disclosed by the assessee is equal to 15.75% of the total receipt of Rs. 20,82,626/-. The return of income and the computation sheet enclosed with the paper book and placed as page…… to …… of P.B. established this fact. The assessing officer