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

condone the delay in filing the appeal before the ld. CIT(Appeals). 11. Since the ld. 1st Appellate Authority has not decided the appeal on merit, therefore, ideal situation is to restore all these issues to the file of ld. CIT(Appeals) for adjudication on merit. But a perusal of the assessment order would reveal that it is also

GRAM NIRMAN MANDAL,NAWADA vs. DC/AC EXEMPTION, CIR, PATNA, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 11, 12& 10(23B). 7) For that, as per assessment order u/s 143(3) assessed income is Rs 3,16,98,714/-and Gross tax liability is Rs 30,09,194/- 8) For that, delay of filling of 10B, was caused due to the negligence of the of the chartered Accountant, assessee should not be punished for mistake

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

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

SAROJ DEVI,PATNA vs. ITO, WARD- 6 (4), PATNA

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

Bench: Shri George Mathan & 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 grounds of appeal hereto are without prejudice to each other. 2. For that the Learned CIT(A) has erred in confirming the Assessment Order dated 16.12.2019 as passed u/s 143(3) read

PATNA SMART CITY LIMITED,PATNA vs. INCOME TAX OFFICER, PTN-W-(21)(91), PATNA

In the result, the appeal of the appellant is dismissed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 144B of the Act after making the following additions: - Sl.No. Particulars Amount (in ₹) 1. Low net profit construction contractors large claim of refund 13,54,095 2. High liabilities as compared to low income of/receipts 2,93,821 3. Forfeiture of bank guarantee 42,28,00,000 3.1 It is further stated in the Statement of Facts filed that

ASSISTANT COMMISSIONER OF INCOME TAX EXEMPTION CIRCLE PATNA, PATNA vs. CHANAKYA NATIONAL LAW UNIVERSITY, NAYAY NAGAR

In the result, this appeal is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Vice- & Shri Sanjay Awasthii.T.A. No.342/Pat/2024 Assessment Year: 2016-17 Acit(Exemption), Patna..........................................................……….……Appellant Vs. Chanakya National Law University, Nayay Nagar.............……...…..…..Respondent Mithapur, Patna, Bihar – 800001. [Pan: Aaajc0528M] Appearances By: Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Appellant. Shri A. K. Rastogi, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 18, 2024 Date Of Pronouncing The Order : November 21, 2024 Order Per Sanjay Awasthi: 1. The Present Appeal Has Been Filed By The Revenue Against The Order Dated 07.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 1.1 In This Case, There Were Primarily Two Issues Which Were Before The Assessing Officer, Namely, The Issue Of Delayed Filing Of Form 10 Which Was Required U/S 11(2) R.W.S. 13(9) Of The Act & Secondly, The Issue Of An Amount Of Rs.3,58,00,000/- Which Was Added As Technically Being A Receipt Which Had Not Been Offered For Tax By The Assessee. Needless To Say, The Amount Of Rs.3,58,00,000/- Was Added & The Benefit Of Carry Forward Of Surplus Income Was Denied Since The Form 10 Was Not Filed In Time. 2. This Matter Was Carried In Appeal Before The Ld. Cit(A) & There The Issue Of Rs.3,58,00,000/- Was Allowed As Relief On The Ground That The Impugned Amount Was Apparently Debited Internally & Shown As

10 not being filed within the time prescribed in the Act/Rules would fatally affect the assessee’s chance of any accumulation as envisaged u/s 11(2) r.w.s. 13(9) of the Act. Though this has not been specifically raised in the grounds of appeal but it is noticed that in the last but one paragraph (Para 8) of the impugned

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

NORTH BIHAR CONSTRUCTION PRIVATE LIMITED,PATNA vs. DCIT CIRCLE-3, DARBHANGA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 243/Pat/2023 Assessment Year: 2014-2015 North Bihar Construction Pvt. Limited,………Appellant Singh Sadan, Veer Kunwar Singh Path, Danapur Cantt., Patna-801503, Bihar [Pan:Aabcn9870B] -Vs.- Deputy Commissioner Of Income Tax,.…...Respondent Circle-3, Darbhanga Darbhanga-846001, Bihar Appearances By: Shri Pankaj Jyoti, C.A., Appeared On Behalf Of The Assessee Shri Ajay Kr. Shukla, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 13, 2024 Date Of Pronouncing The Order: December 10, 2024 O R D E R

13, 2024 Date of pronouncing the order: December 10, 2024 O R D E R Per Duvvuru RL Reddy, Vice-President (KZ):- The present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 31st January, 2023 passed for Assessment Year 2014-15. 1 North

AMAR NATH SINGH,ARA vs. ITO, NFAC, DELHI

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

Bench: The Itat. In This Regard, The Assessee Has Given Explanation Which Is As Under:

condone the delay and the appeal is taking for adjudication. 3 Amar Nath Singh 4. Briefly stated the facts of the case are that the assessee filed return of income on 04.01.2018 declaring total income at Rs. 5,03,010/- as per information with the income tax department. The assessee had deposited cash in his bank account maintained at Punjab

ASHUTOSH KUMAR PRABHAT,ARRAH vs. PCIT-1, PATNA

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

Bench: Shri George Mathan & 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 grounds of appeal hereto are without prejudice to each other. 2. For that the order of the Id. Principal Commissioner of Income Tax-1, Patna, is bad both

XAVIERS CONSTRUCTION PVT LTD,PATNA vs. ITO WARD- 2 (2), PATNA

In the result, the appeal of the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 349/Pat/2023 Assessment Year: 2015-2016 Xaviers Construction Pvt. Limited,....……Appellant House No. 239, Lodipur, Patna-800001, Bihar [Pan:Aaacx0342D] -Vs.- Income Tax Officer,………………………….....Respondent Ward-2(2), Patna Appearances By: Shri Anjan Biswas, Fca, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: February 13, 2025 Date Of Pronouncing The Order: March 21, 2025 O R D E R

delay is condoned. 4. Brief facts of the case are that the appellant-assessee is a Private Limited Company, doing its business in developing Real Estate and engaged in civil contract work. The assessee has filed its return of income for the assessment year 2015-16 declaring total income of Rs.5,47,040/-. The case was selected for scrutiny. Accordingly

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

13. The issue which needs adjudication is that where no notice under section 143(2) of the Act has been issued to assessee, can the assessment be completed under section 143(3) of the Act? Further, whether in the circumstances where no return of income has been filed and no notice under section 143(2) of the Act could

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

13. The issue which needs adjudication is that where no notice under section 143(2) of the Act has been issued to assessee, can the assessment be completed under section 143(3) of the Act? Further, whether in the circumstances where no return of income has been filed and no notice under section 143(2) of the Act could

SIDDHI GUPTA,AURANGABAD vs. ITO, WARD- 3 (3), AURANGABAD

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. Nos. 355 & 356/Pat/2023 Assessment Year: 2017-2018 Siddhi Gupta,…………………..…………....……Appellant S/O. Gopal Prasad Gupta, Masjid Road, Near Rath, Durga Chowk, Obra, Aurangabad-824101, Bihar [Pan:Aufps5370G] -Vs.- Income Tax Officer,…………………………....Respondent Ward-3(3), Aurangabad, Near Block More, Aurangabad-824101, Bihar

13, 2025 O R D E R Per Duvvuru RL Reddy, Vice-President (KZ):- The present appeals bearing ITA Nos. 355/PAT/2023 and 356/PAT/2023 are directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National 1 ITA Nos. 355 & 356/PAT/2023 (A.Y. 2017-2018) Siddhi Gupta Faceless Appeal Centre (NFAC), Delhi dated 18th September

SIDDHI GUPTA,AURANGABAD vs. ITO, WARD- 3 (3), AURANGABAD

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. Nos. 355 & 356/Pat/2023 Assessment Year: 2017-2018 Siddhi Gupta,…………………..…………....……Appellant S/O. Gopal Prasad Gupta, Masjid Road, Near Rath, Durga Chowk, Obra, Aurangabad-824101, Bihar [Pan:Aufps5370G] -Vs.- Income Tax Officer,…………………………....Respondent Ward-3(3), Aurangabad, Near Block More, Aurangabad-824101, Bihar

13, 2025 O R D E R Per Duvvuru RL Reddy, Vice-President (KZ):- The present appeals bearing ITA Nos. 355/PAT/2023 and 356/PAT/2023 are directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National 1 ITA Nos. 355 & 356/PAT/2023 (A.Y. 2017-2018) Siddhi Gupta Faceless Appeal Centre (NFAC), Delhi dated 18th September

ALMAHAD TRUST ,PATNA vs. ITO EXEMPTION, WARD-1, PATNA , PATNA

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

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

13 months and 17 days in the tiling of the present appeal. 5. That the aforesaid trust as filed a petition for condonation of delay un filing the appeal. In paragraph 4 of the petition, it has been stated that pursuant to the setting aside of the order in appeal by the learned Commissioner of Income Tax appeal wherein