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

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

RAM KUMAR,SUPAUL vs. ITO, 3(5), SAHARSA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

143(3)/147 of the Act, dated 03.12.2019. 1.1. The Registry has informed that the appeal filed by the assessee is barred by limitation by 156 days. An application seeking condonation of delay has been filed by the assessee for condoning the delay stating as follows: “1. That this application is filed for condonation of delay in the filing

M/S NORTH BIHAR DISTRIBUTOR,PURNEA vs. ITO, WARD-3(1), PURNEA

In the result, appeals of the assessee are dismissed

Bench: Shri Rajpal Yadav & Shri Girish Agrawal

condone the delay in filing the appeal before us and take up the matter for adjudication. 4. Grounds taken by the assessee are:- (a) in ITA No. 48/Pat/2020: 1. For that the appellate order passed u/s. 250 of the Act is bad in law. 2. For that the ld. CIT(appeals) has not been justified in confirming the order passed

M/S NORTH BIHAR DISTRIBUTOR,PURNEA vs. ITO, WARD-3(1), PURNEA

In the result, appeals of the assessee are dismissed

Bench: Shri Rajpal Yadav & Shri Girish Agrawal

condone the delay in filing the appeal before us and take up the matter for adjudication. 4. Grounds taken by the assessee are:- (a) in ITA No. 48/Pat/2020: 1. For that the appellate order passed u/s. 250 of the Act is bad in law. 2. For that the ld. CIT(appeals) has not been justified in confirming the order passed

RAVINDRA KUMAR,PATNA vs. ITO, WARD-4(5), PATNA

The appeal of the assessee is allowed for statistical purposes

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

143(1) was passed on 30.03.2019. 5. Dissatisfied with this adjustment, assessee filed the appeal before the ld. CIT(Appeals). This appeal was time 3 Assessment Year: 2017-2018 Rabindra Kumar barred by 208 days and the assessee has filed an application for condonation of delay. The ld. CIT(Appeals) condoned the delay. The ld. CIT(Appeals) has dismissed

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

143(3) read with section 153A of the Act. Considering the fact that assessee had declared additional income in the return filed u/s 153A of the Act, the learned Assessing Officer initiated the penalty proceedings u/s 270A of the Act for alleged under reporting of income. However, the assessee filed an application belatedly u/s 270AA of the Act for grant

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

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