GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

condone the delay and admit the appeals for hearing on merits. 3. As the issues raised in the present appeals are identical, they were heard together and are being disposed off by way of this common order. For the sake of convenience, we first take up the assessee’s appeal for Assessment Year 2015-16 and our decisions therein shall

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

condone the delay and admit the appeals for hearing on merits. 3. As the issues raised in the present appeals are identical, they were heard together and are being disposed off by way of this common order. For the sake of convenience, we first take up the assessee’s appeal for Assessment Year 2015-16 and our decisions therein shall

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

condone the delay and admit the appeals for hearing on merits. 3. As the issues raised in the present appeals are identical, they were heard together and are being disposed off by way of this common order. For the sake of convenience, we first take up the assessee’s appeal for Assessment Year 2015-16 and our decisions therein shall

VIJAY KUMAR JHA,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

condoning the delay of 283 days for all the appeals stating that he was under the treatment of mental illness after the search and seizure

VIJAY KUMAR JHA,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

condoning the delay of 283 days for all the appeals stating that he was under the treatment of mental illness after the search and seizure

VIJAY KUMAR JHA,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

condoning the delay of 283 days for all the appeals stating that he was under the treatment of mental illness after the search and seizure

VIJAY KUMAR JHA,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Laxmi Prasad Sahui.T.A. Nos. 412, 413, 414 & 415/Pat/2025 Assessment Years: 2013-14, 14-15, 15-16 & 2016-17 Vijay Kumar Jha,…………….……………………..Appellant Kanhaulidih, Near Sanskrit College, Malighat, P.O. Ramna, P.S. Mithanpura, Muzaffarpur-842002, Bihar [Pan:Adgpj3007M] -Vs.- Assistant Commissioner/Deputy Commissioner Of Income Tax,………………………………………..Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, New Nehru Stadium, Sikandarpur, Muzaffarpur-842001, Bihar Appearances By: Shri Anuj Ganguli, Ca, Appeared Filed On Behalf Of The Assessee Shri Manab Adak, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: January 20, 2026 Date Of Pronouncing The Order: January 22, 2026 O R D E R

condoning the delay of 283 days for all the appeals stating that he was under the treatment of mental illness after the search and seizure

MITHILESH KUMAR CHOUBEY,PATNA vs. DCIT/ACIT CEN CIR2,PAT, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the order passed by The Ld. AO is illegal and invalid and against the law as the addition is unsustainable based on the facts of the case. 2. For that the appellant submits

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

seizure and survey operation u/s 132 of the Act and 133A of the Act, conducted on the business premises of Nand Kumar Prasad Sah and other related concerns on 17th September, 2020, and assessee was also subjected to search and certain incriminating material / loose paper / tally data were found. Pursuant to the of search, notice u/s 153A

KAMLA DEVI JAYDAYAL JAIN PRIVATE LIMITED,MUZAFFARPUR vs. ASSISTANT COMMISIONER OF INCOME TAX, MUZAFFARPUR

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

condone the delay and admit the appeal for adjudication. 2. The Assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the order of assessment passed by the Ld. CIT(Appeals), Patna is bad in the law and fact. 2. For that disallowance of expense amounting to Rs. 4,16,006 on estimate basis

PANKAJ KUMAR,MUZAFFARPUR vs. COMMISSIONER OF INCOME TAX, PATNA

In the result, all the four appeals of the assessee are allowed for statistical purposes

delay is condoned, and the appeals are admitted for adjudication on merits.\n3. First we take up as a lead ITA No. 649/Patna/2024case A.Y. 2017-18 and finding of this will apply to other connected appeal mutatis mutandis. A search and seizure

PANKAJ KUMAR,MUZAFFARPUR vs. COMMISSIONER OF INCOME TAX, PATNA

In the result, all the four appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

delay is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up as a lead ITA No. 649/Patna/2024case A.Y. 2017–18 and finding of this will apply to other connected appeal mutatis mutandis. A search and seizure

PANKAJ KUMAR,MUZAFFARPUR vs. COMMISSIONER OF INCOME TAX, PATNA

In the result, all the four appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

delay is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up as a lead ITA No. 649/Patna/2024case A.Y. 2017–18 and finding of this will apply to other connected appeal mutatis mutandis. A search and seizure

PANKAJ KUMAR,MUZAFFARPUR vs. COMISSIONER OF INCOME TAX, PATNA

In the result, all the four appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

delay is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up as a lead ITA No. 649/Patna/2024case A.Y. 2017–18 and finding of this will apply to other connected appeal mutatis mutandis. A search and seizure