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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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

1) of the Act on 11th November, 2017, declaring income of ₹8,35,425/-. Subsequently, search, 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

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 by the AO u/s 36(1

MANISHA KUMARI,PATNA vs. WARD-5(2), PATNA, PATNA

In the result, the appeal of the assessee is allowed for statistical purposes in the terms indicated above

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.286/Pat/2025 Assessment Year: 2016-17 Manisha Kumari…..……………..………. …………………....Appellant 5, Indrapuri, Keshri Nagar, Indrapuri, Patna, Pin-800024. Bihar.. [Pan: Afmpk0739D] Vs. Ito, Ward-5(2), Patna ......…..……………..………………….…..... Respondent Appearances By: Shri Shikesh Jha, Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.11.2024 Of The Learned Cit(A), Nfac Relating To The Assessment Year 2016–17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual Who Filed A Return Of Income Declaring Total Income Of ₹2,29,470 For The Assessment Year 2016–17. Based On Information That Income To The Tune Of ₹7,50,000 Had Escaped Assessment, The Assessing Officer Recorded Reasons For Reopening The Case & Obtained The Necessary Approval From The Competent Authority. Consequently, Notice Under Section 148 Of The Act Was Issued To The Assessee. No Return Of Income Was Filed In Response To The Said Notice. Thereafter, Notices Under Section 142(1) Along With

1) along with I.T.A. No.286/Pat/2025 Manisha Kumari show-cause notices were issued, however, the assessee failed to comply with the same. Accordingly, the Assessing Officer completed the assessment ex parte under Sections 144 and 147 of the Act, treating the claimed agricultural income of ₹7,50,000 as “income from other sources.” 3. Aggrieved by the order of the Assessing

KUMAR SUMAN SINGH,PATNA vs. DCIT CENTRAL CIRCLE-2, PATNA

132(1) of the Act was conducted on\n19.02.2004 in the case of the assessee as well as his\nassociates/relatives. In this search operation, substantial investments in\nform of movable and immoveable properties were discovered which was\nalleged to have been unaccounted income of the assessee. The\ninvestigation revealed significant undisclosed income from activities\nrelated to examinations and recruitment process

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 operation under Section 132 of the Act was conducted in the case of the Nand Kishore Prasad Shah

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 operation under Section 132 of the Act was conducted in the case of the Nand Kishore Prasad Shah

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 operation under Section 132 of the Act was conducted in the case of the Nand Kishore Prasad Shah

KUMAR SUMAN SINGH,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

In the result, I.T.A. Nos

delay of 132 days in filing the\ninstant appeals. The assessee has submitted applications for\ncondonation of delay citing reasonable grounds. After considering the\naverments made in the applications, we condone the delay.\n3. We also find that no one has appeared on behalf of the assessee.\nOn perusal of records, we notice that multiple dates of hearing were\nscheduled