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

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 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

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

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

Section 270A(A) of the Act. He further referring to the judgement of Hon'ble Delhi High Court in case of PCIT vs. Neeraj Jindal (2017) 393 ITR 0001 (Delhi), stated that once the assessee is subjected to search and notice u/s 153A of the Act is issued for furnishing the return and the assessee furnished ITA Nos.163

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

condoned the delay in filing the appeals. The Tribunal dismissed Ground No.1 regarding the legality of proceedings u/s 153A, as the search was based on credible information. Ground No.2 concerning household expenses was dismissed. Ground No.3 regarding the inclusion of income assessed under an alias name was upheld. For AY 2001-02, the addition on account of low withdrawal

AARIF ALI,SIWAN vs. AC/DCIT, CENTRAL CIRCLE, MUZAFFARPUR

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations 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 Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

delay in filing the appeals is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up ITA No. 278/Patna/2025) as a lead case (A.Y. 2013-14) 4. The brief facts of the case are that the assessee was found in possession of cash amounting to ₹10,49,200, which was seized by the Government Railway

AARIF ALI,SIWAN vs. AC/DCIT, CENTRAL CIRCLE, MUZAFFARPUR

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations 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 Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

delay in filing the appeals is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up ITA No. 278/Patna/2025) as a lead case (A.Y. 2013-14) 4. The brief facts of the case are that the assessee was found in possession of cash amounting to ₹10,49,200, which was seized by the Government Railway

AARIF ALI,SIWAN vs. AC/DCIT, CENTRAL CIRCLE, MUZAFFARPUR

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations 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 Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

delay in filing the appeals is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up ITA No. 278/Patna/2025) as a lead case (A.Y. 2013-14) 4. The brief facts of the case are that the assessee was found in possession of cash amounting to ₹10,49,200, which was seized by the Government Railway

AARIF ALI,SIWAN vs. AC/DCIT, CENTRAL CIRCLE, MUZAFFARPUR

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations 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 Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

delay in filing the appeals is condoned, and the appeals are admitted for adjudication on merits. 3. First we take up ITA No. 278/Patna/2025) as a lead case (A.Y. 2013-14) 4. The brief facts of the case are that the assessee was found in possession of cash amounting to ₹10,49,200, which was seized by the Government Railway