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

89,730/- for A.Y.2016-2017. Consequently, the Assessing Officer framed the assessment u/s.153A of the Act for A.Y.2014-2015 & 2015-2016 and u/s. 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

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

89,730/- for A.Y.2016-2017. Consequently, the Assessing Officer framed the assessment u/s.153A of the Act for A.Y.2014-2015 & 2015-2016 and u/s. 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

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.

89 (Pat.) held that the words 'reason to believe' do not mean 'reason to suspect'. Section 147 does not give unfettered discretion to the income-tax authorities. The belief entertained by the authorities must not be arbitrary or irrational. It must be reasonable or, in other words, it must be based on reasons which are relevant and material—Ganga Saran

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/-“

89,40,066/-“ 2 Sudhir Kumar A.Y. 2010-11 2.1. Assessee went into appeal before the ld. CIT(A) challenging the additions so made, who gave relief on certain additions and the appeal was partly allowed. Aggrieved, the assessee is in appeal before the Tribunal in respect of additions sustained by the ld. CIT(A). Assessee has taken as many