RENU DEVI,PATNA vs. ITO, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 672/Pat/2024 Assessment Year: 2016-2017 Renu Devi,……………………………....….………Appellant D/79, P.C. Colony, Lohia Nagar, Kankarbagh, Patna-800020, Bihar [Pan:Algpd4522P] -Vs.- Income Tax Officer,………………………...…….Respondent Ward-6(2), Patna Appearances By: Shri Sudipta Sannigrahi, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 24, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

section 45(5A) at the time of execution of JDA, the capital gains as on the date of JDA is to be considered

VINOD YADAV,PATNA vs. ITO, WARD- 6 (3), PATNA

In the result, the appeal of the assessee is partly allowed for statistical\npurposes

45", "Section 48", "Section 147", "Section 148", "Section 133(6)", "Section 50C", "Section 54F" ], "issues": "Whether the Joint Development Agreement constituted a 'transfer' of property leading to capital gains

HARI NARAYAN GUPTA (HUF),PATNA vs. ITO, WARD- 6 (5), PATNA

In the result, the appeal of the assessee is allowed

gain arose from it. Relying on various High Court and Apex Court decisions, the Tribunal found no merit in the AO's addition.", "result": "Allowed", "sections": ["Section 2(47)(v)", "Section 45", "Section 48", "Section 50C", "Section 53A", "Section 54F"], "issues": "Whether the Land Development Agreement constituted a transfer of property attracting capital

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]

capital gain on certain long term gain during the course of assessment proceedings. The AO observed that the assessee has taken unsecured loan of Rs. 34,00,000/- and accordingly called upon the assessee to furnish the details of names and addresses of the persons along with confirmation letters, bank statements and other evidences. The assessee replied the queries

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]

capital gain on certain long term gain during the course of assessment proceedings. The AO observed that the assessee has taken unsecured loan of Rs. 34,00,000/- and accordingly called upon the assessee to furnish the details of names and addresses of the persons along with confirmation letters, bank statements and other evidences. The assessee replied the queries

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]

capital gain on certain long term gain during the course of assessment proceedings. The AO observed that the assessee has taken unsecured loan of Rs. 34,00,000/- and accordingly called upon the assessee to furnish the details of names and addresses of the persons along with confirmation letters, bank statements and other evidences. The assessee replied the queries

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]

capital gain on certain long term gain during the course of assessment proceedings. The AO observed that the assessee has taken unsecured loan of Rs. 34,00,000/- and accordingly called upon the assessee to furnish the details of names and addresses of the persons along with confirmation letters, bank statements and other evidences. The assessee replied the queries

KUMAR ARUNOSAYA,PATNA vs. A.O., CIRCLE-6, 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]

capital gain on certain long term gain during the course of assessment proceedings. The AO observed that the assessee has taken unsecured loan of Rs. 34,00,000/- and accordingly called upon the assessee to furnish the details of names and addresses of the persons along with confirmation letters, bank statements and other evidences. The assessee replied the queries

PUSHPA KUMARI,PATNA vs. ITO, WARD-6(2), PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 7/Pat/2022 Assessment Year: 2015-2016 Pushpa Kumari,…………………..…...…………Appellant Rashtiriya Ganj, Station Road, Phulwari Sharif, Patna-801505, Bihar [Pan:Agmpk8844Q] -Vs.- Income Tax Officer,…..………………………...Respondent Ward-6(2), Patna Appearances By: Shri Prasoon Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 28, 2024 Date Of Pronouncing The Order: December 31, 2024 O R D E R

capital gains by invoking the provisions of section 45 read with section 2(47) of the Income Tax Act. 3. On being

SONAM RAJ,NEW DELHI vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

section 2(47)(v) of the Act in the computation of taxable income without assigning proper and valid reason and justification. The learned Assessing Officer have mis-construed the fact by mis-reading /ignoring the provision governing and reckoning of deemed transfer. Computation of long term capital gain in the order on various facets was wrong, erroneous, unjustified, incorrect

VIBHUTI BHUSHAN SINHA,DWARKA vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

section 2(47)(v) of the Act in the computation of taxable income without assigning proper and valid reason and justification. The learned Assessing Officer have mis-construed the fact by mis-reading /ignoring the provision governing and reckoning of deemed transfer. Computation of long term capital gain in the order on various facets was wrong, erroneous, unjustified, incorrect

DOLLY GHOSH,BHAGALPUR vs. ACIT CENTRAL CIRCLE 1 PATNA, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

capital gains chargeable under section 45; (vii) the profits and gains of any business of insurance carried on by a mutual

BAIJU ROY,PATNA vs. ITO, WARD-4(2), PATNA

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

sections and on the basis of report received from the Land Acquisition Officer and Circle Officer, the land in question is taxable u/s 45(5) of the Income-tax Act,1961 as Capital Gain

DIPAK KUMAR SINGH & SONS HUF,PATNA vs. INCOME TAX OFFICER WARD 6(2), PATNA

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

Bench: the Ld. CIT(A), the assessee claimed that the delay was on account of ignorance of law and the assessee was alerted for filing the appeal only when they received a notice proposing levy of penalty u/s 271(1)(c) of the Act. Thereafter, the Ld. CIT(A) has discussed the issue of delayed filing with the help of several authorities on the subject and has declined to condone the said delay due to which the appeal was dismissed. 3.1 Further aggrieved with the action of Ld. CIT(A), the assessee is

capital gains solely on the basis of the development agreement without taking notice of Section 45 (5A) inserted by the Finance

SHARDHA DEVI,PATNA vs. INCOME TAX OFFICER, PATNA

In the result, appeal filed by the assessee is allowed for statistical\npurposes

section 45(SA) of the Act, the capital gain would arise in the year\nthe completion certificate by a competent

ANUP KUMAR,PATNA vs. ITO, WARD 6(4), PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 401/Pat/2024 Assessment Year: 2016-2017 Anup Kumar,……………..………….…….....……Appellant Sultanpur, Danapur, Patna-801503, Bihar [Pan:Cdupk6764J] -Vs.- Income Tax Officer,……………………………….Respondent Ward-6(4), Patna, Lok Nayak Jai Prakash Bhawan, New Dak Bunglow, Patna-800001, Bihar Appearances By: Shri Alok Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue

section 147 of the Income Tax Act on 28.11.2019 assessing the long-term capital gain at Rs.51,45,000/- and deducted

HAMID ALI,ROHTAS vs. ITO, WARD- 3 (4), SASARAM

In the result, ITA No.356/Pat/2025 is partly allowed for statistical purposes and ITA No

Bench: Ms. Madhumita Roy & Shri Rakesh Mishraita Nos.356 & 357/Pat/2025 Assessment Years: 2018-19 Hamid Ali…..……………..……………………….……….……….……Appellant C/O Gulam Murtaza Zakki Shaheed, Sasaram, Rohtas, Bihar – 821115. [Pan: Atppa8563N] Vs. Ito, Ward-3(4), Sasaram.…………………………….....……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 06, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Madhumita Roy: Both The Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 12.12.2024 Passed By Nfac, Delhi Arising Out Of The Orders Dated 23.02.2021 & 23.08.2021 Passed U/S 143(3) & U/S 270A Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Respectively For Assessment Year 2018-19. Ita No.356/Pat/2025 Relates To Quantum Order Whereas Ita No.357/Pat/2025 Relates To Penalty Order.

45,200/- and index improvement cost of Rs.15,64,576/-. The assessee declared stamp duty value of the said property at Rs.43,17,000/-. It is the case of the revenue that in spite of requests made to the assessee for submission of proof of cost of acquisition, proof of improvement, sale deed and reason for not taking stamp duty

HAMID ALI,ROHTAS vs. ITO, WARD- 3 (4), SASARAM

In the result, ITA No.356/Pat/2025 is partly allowed for statistical purposes and ITA No

Bench: Ms. Madhumita Roy & Shri Rakesh Mishraita Nos.356 & 357/Pat/2025 Assessment Years: 2018-19 Hamid Ali…..……………..……………………….……….……….……Appellant C/O Gulam Murtaza Zakki Shaheed, Sasaram, Rohtas, Bihar – 821115. [Pan: Atppa8563N] Vs. Ito, Ward-3(4), Sasaram.…………………………….....……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 06, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Madhumita Roy: Both The Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 12.12.2024 Passed By Nfac, Delhi Arising Out Of The Orders Dated 23.02.2021 & 23.08.2021 Passed U/S 143(3) & U/S 270A Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Respectively For Assessment Year 2018-19. Ita No.356/Pat/2025 Relates To Quantum Order Whereas Ita No.357/Pat/2025 Relates To Penalty Order.

45,200/- and index improvement cost of Rs.15,64,576/-. The assessee declared stamp duty value of the said property at Rs.43,17,000/-. It is the case of the revenue that in spite of requests made to the assessee for submission of proof of cost of acquisition, proof of improvement, sale deed and reason for not taking stamp duty