G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

delay is condoned and we proceed to decide the appeals on merit. 6 ITA No. 308/PAT/2024 (A.Y. 2019-2020) G D Mother Educational Society 8. The assessee has filed application for permission to raise additional grounds of appeal. The assessee has sought to raise two additional grounds of appeal in each year. The application of the assessee reads as under

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

delay is condoned and we proceed to decide the appeals on merit. 6 ITA No. 308/PAT/2024 (A.Y. 2019-2020) G D Mother Educational Society 8. The assessee has filed application for permission to raise additional grounds of appeal. The assessee has sought to raise two additional grounds of appeal in each year. The application of the assessee reads as under

ITO, WARD-4(1), PATNA vs. JAGDISH RAY, PATNA

In the result, the appeal of revenue-ITA No

condone the said delay and admit the appeal for adjudication of the issues raised before us on merits. 4. First we take up the revenue’s appeal-ITA No. 102/Pat/20 for the AY 2015-15. 5. The only issue for our consideration is that whether the ld. CIT(A) erred in granting relief

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

delay is condoned and the appeal is admitted for adjudication. 2. The Revenue is in appeal before the Tribunal raising the following grounds of appeal: “i) On the facts and in the circumstances of the case, the Ld. CIT(A) erred in law by deleting the disallowance of Rs. 43,67,25,641/- made

M/S PARWATI EDUCATIONAL & WELFARE TRUST,PATNA vs. PR.CIT-CENTRAL, PATNA

In the result, both the appeals filed by the assessee are allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma)

condone the delay of 25 days and admit the appeal for adjudication. 3. The assessee is in appeal before the Tribunal raising the following grounds: Assessment Year 2011-12: “1. That the Hon'ble PCIT, Patna erred in appreciating the facts properly. 2. That the Hon'ble PCIT erred in treating the assessment order passed by the learned assessing officer

M/S PARWATI EDUCATIONAL & WELFARE TRUST,PATNA vs. PR.CIT-CENTRAL, PATNA

In the result, both the appeals filed by the assessee are allowed

Bench: Sri Manish Borad & Sri Sonjoy Sarma)

condone the delay of 25 days and admit the appeal for adjudication. 3. The assessee is in appeal before the Tribunal raising the following grounds: Assessment Year 2011-12: “1. That the Hon'ble PCIT, Patna erred in appreciating the facts properly. 2. That the Hon'ble PCIT erred in treating the assessment order passed by the learned assessing officer

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

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

SRIRAM ENTERPRISES,PATNA vs. PCIT (CENTRAL), PATNA

In the result, the appeal of the assessee is allowed

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 76/Pat/2023 Assessment Year: 2018-2019 Sriram Enterprises,………………………..........Appellant C/O. Nirmal & Associates, Nepali Kothi, Opposite Gasoline Petrol Pump, Boring Road, Patna-800001 [Pan:Aarfs8853J] -Vs.- Principal Commissioner Of Income Tax (Central), Patna,…………………………………..……………..Respondent, Bihar-800001 Appearances By: Shri Nishant Maitin, C.A., Appeared On Behalf Of The Assessee Md. A.H. Chowdhary, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : 5Th March, 2024 Date Of Pronouncing The Order: May 8Th, 2024 O R D E R

condone the delay and proceed to decide the appeal on merit. 4. Brief facts of the case are that the assessee is a partnership firm engaged in the business of Government Civil Contractor & Sub-contractor and involved in the infrastructure development and maintenance such as roads, bridges, railways tunnels, etc. Income of Rs.4,25,44,130/- declared

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.

condone the delay and proceed to decide the appeal of the assessee on merits. P a g e 1 | 71 Assessment Year : 2010 -2011 3. The assessee has raised the following grounds of appeal” “1. For that the CIT(A) has erred in affirming the order of the Assessing Officer passed u/s.143(3)/147 wherein the Assessing Officer has assessed

VEENA DEVI,MUZAFFARPUR vs. PR.CIT-1, PATNA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Dr. Manish Borad, Hon’Blei.T.A. No. 41/Pat/2021 Assessment Year: 2011-12 Veena Devi Pr. Cit, Patna-1 Vs Krishnapuri, Nh 28 Bhagwanpur Chowk Muzaffarpur - 842001 [Pan: Aoyps8291P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ashish Maskara, Advocate Revenue By : Smt. Rinku Singh, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 29/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 06/06/2023 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 Learned Principal Commissioner Of Income Tax, Patna-1, (Hereinafter The “Ld. Pr. Cit”) Dt. 23/03/2021, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2011-12. 2. The Registry Has Pointed Out That There Is A Delay Of Eighteen (18) Days In Filing Of This Appeal In Time Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Stating The Reasons Of Delay. After Perusing The Same, We Find That The Assessee Was Prevented By Sufficient Cause From Filing The Appeal In Time Before The Tribunal. Hence, The Delay Is Condoned & The Appeal Is Admitted. 3. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Order Passed U/S 263 Of The It Act By The Ld Pcit, Patna Is Wrong, Illegal, Arbitrary & Against The Fact & Circumstances Of The Case.

delay is condoned and the appeal is admitted. 3. The assessee has raised the following grounds of appeal:- “1. For that the order passed U/s 263 of the IT Act by the Ld PCIT, Patna is wrong, illegal, arbitrary & against the fact & circumstances of the case. I.T.A. No. 41/Pat/2021 Assessment Year: 2011-12 Veena Devi 2 2. For that