DCIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

1) of the Act along with questionnaires as annexure whereby it was show caused as to why the income from capital gain should not be added to the income of the assessee due to non declaration of the same in the return of income. The ld. A.R argued that by misconstruing the provisions of section 139

ACIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

1) of the Act along with questionnaires as annexure whereby it was show caused as to why the income from capital gain should not be added to the income of the assessee due to non declaration of the same in the return of income. The ld. A.R argued that by misconstruing the provisions of section 139

KUMAR ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

1) of the Act along with questionnaires as annexure whereby it was show caused as to why the income from capital gain should not be added to the income of the assessee due to non declaration of the same in the return of income. The ld. A.R argued that by misconstruing the provisions of section 139

ACIT, CENTRAL CIRCLE-2, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

1) of the Act along with questionnaires as annexure whereby it was show caused as to why the income from capital gain should not be added to the income of the assessee due to non declaration of the same in the return of income. The ld. A.R argued that by misconstruing the provisions of section 139

MASUDAN TANTI,BHAGALPUR vs. CIT, NFAC, DELHI

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

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2013-14

capital account etc. A copy of the notice u/s 142(1) dated 02.12.2021 was also got served physically through the Verification Unit but despite being provided with several opportunities, no compliance was made nor any reply was filed. Meanwhile, information was collected from UCO Bank and it was found that the total amount credited in the bank account

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.

Section 147 of the Act, the reopening cannot be held valid unless any income chargeable to tax has escaped assessment for such Assessment Year by reason of the failure on the part of the assessee to file a return u/s 139 of the Act or in response to the notice issued u/s 142(1

ACIT, PATNA vs. NEW ERA SOCIAL DEVELOPMENT WELFARE SOCIETY, PATNA

Appeal is treated as allowed for statistical purposes

139(1). Hence, exemption under section 11 and 12 is also not applicable and the exemption claimed of Rs. 5,80,39,300/-plus other section in ITR is hereby disallowed by the undersigned. After due consideration of facts & circumstances and verification of documents available in this office, the income of the assessee AOP/BOI is computed u/s 144 i.e. Best

VIVEK KUMAR RANA,PATNA vs. ASSESSEMENT UNIT, DELHI

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 115/Pat/2025 Assessment Year: 2016-2017 Vivek Kumar Rana,…….……….………..………Appellant 101, Artak Apartment, Ashiana Road, B.V. College, S.O. Rukanpura, Patna-800014, Bihar [Pan:Adhpr8630D] -Vs.- Assessment Unit, Delhi,………………….…....Respondent Ito/Nfac, Delhi Appearances By: Shri Manish Sinha, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 17, 2025 Date Of Pronouncing The Order: June 24, 2025 O R D E R

capital gain and initiated penalty proceedings under section 271(1)(c) of the Act for concealment of income and furnishing of inaccurate particulars of income. Thus ld. Assessing Officer determined the total income of the assessee at Rs.47,99,250/- (income as per return of income filed u/s 139

MAHENDRA PRASAD,EAST CHAMPARAN vs. ASSESSMENT UNIT, ITD, DELHI, DELHI

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

Bench: Shri George Mathan & Shri Rakesh Mishra

139(1) of Act on 26.12.2021 declaring total income of Rs. 67,28,730/-. The assessee had declared income of Rs. 64,13,266/- under the head "Profits and Gains from I.T.A. No.: 717/PAT/2024 Assessment Year: 2021-22 Mahendra Prasad. Business or Profession" and income of Rs. 5,00,466/- under the head "Income from Other Sources". The assessee