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

M/S GEETANJALI ESTATE PVT LTD,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is dismissed

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

delay in filing the appeal be condoned. 9 Assessment Year: 2013-2014 M/s. Geetanjali Estate Pvt. Ltd. 9. On due consideration of the record, we find that Shri N.K. Sinha, Advocate, attended the proceeding undertaken under section 263

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

VIRENDRA SAH,PURNEA vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, DELHI

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 132/Pat/2025 Assessment Year: 2018-2019 Virendra Sah,…………….……….………..………Appellant Madhavnagar Tirasi Tola, Bhawanipur, Purnea-854204, Bihar [Pan:Gvdps7989Q] -Vs.- Assessment Unit, ………………………….…....Respondent Income Tax Department, Nfac, Delhi Appearances By: None Appeared On Behalf Of The Assessee Shri Ashwani Kumar Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 17, 2025 Date Of Pronouncing The Order: June 24, 2025 O R D E R

263 days. Hence the delay is condoned. 4. Brief facts of the case are that the assessee is engaged in sale of Maize (Food Grain). The assessee has not furnished his return of income for the AY 2018-19. During the year under consideration, the assessee has debited an amount of Rs.2,44,26,100/- from his current bank account

NORTH BIHAR POWER DISTRUBUTION CO. LTD,PATNA vs. PR. CIT-1, PATNA

In the result, appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2017-18

condone the delay and proceed to admit the appeal for hearing. 3. The assessee has taken four grounds of appeal which are reproduced as under: “1. Ground 1: The learned PCIT has erred in law, for issuance of notice [DIN & Notice No: ITBA/REV/F/REV1/2021-22/1 038620636(1) Dated 11/01/2022, attachment thereon] and passed order [DIN & Order No: ITBA/REV/F/REV5/2021- 22/1042288650(1) dated 31/03/2022

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

DEEPAK SHRAWAN BUDHIA,MUMBAI vs. PR. COMMISSIONER OF I.T., PATNA-1, PATNA

In the result, appeal of the assessee is dismissed

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

263 of the I.T. Act, 1961 on account of disallowance of expenditure on account of non-deduction of TDS on freight as per provisions of section 40(a)(ia) of the 1. T. Act, 1961 was passed without considering all provisions of Sec 147 and without considering its exemption provisions. 5. For that, the order was passed without considering that

RANJEET KUMAR,MUZAFFARPUR vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is dismissed

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

condone the delay in filing the appeal and proceed to decide it on merit. 4. This appeal was filed in 2022. It is to be decided on priority being an appeal filed against the order passed under section 263

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

SONAM RAJ,NEW DELHI vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

263 days. A separate application has been filed for condonation of delay, wherein, it has been pleaded that the appellant could not file the appeal in time due to the Covid Pandemic, therefore, considering the application, the delay in filing the present appeal is hereby condoned. The assessee in this appeal has taken the following grounds of 3. appeal

VIBHUTI BHUSHAN SINHA,DWARKA vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

263 days. A separate application has been filed for condonation of delay, wherein, it has been pleaded that the appellant could not file the appeal in time due to the Covid Pandemic, therefore, considering the application, the delay in filing the present appeal is hereby condoned. The assessee in this appeal has taken the following grounds of 3. appeal

RAGHUNATH SARAOGI,DURGAPURR vs. PCIT, CENTAL, PATNA

In the result, the appeal of the assessee is dismissed as withdrawn

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.226/Pat/2022 Assessment Year: 2012-13 Raghunath Saraogi…………………………………………………….…..……Appellant 5/2 Bengal Ambuja City Centre, Durgapur-713216. [Pan: Ajips7251E] Vs. Pcit(Central), Patna……............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Vishal Agarwal, Ar, Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2024 Date Of Pronouncing The Order : December 17, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Against The Order Dated 22.02.2022 Of The Pcit (Central), Patna [Hereinafter Referred To As ‘Pcit’] Exercising His Revision Jurisdiction U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Ld. Ar Submitted That There Is A Delay Of 59 Days In Filing The Instant Appeal. The Assessee Has Submitted An Application For Condonation Of Delay Citing Valid & Proper Reasons. After Considering The Averments Made In The Application, We Condone The Delay. 2.1 The Ld. Counsel For The Assessee Has Further Submitted That The Assessee Has Opted For Direct Tax Vivav Se Vishwas Scheme, 2024 (Hereinafter Referred To As The ‘Scheme’) & Has Received Form 2 Certificate Under Sub-Section (1) Of Section 92 Of The Finance (No.2) Act, 2024, Wherein, It Is Determined That The Assessee Has To Pay

263 of the Income Tax Act (hereinafter referred to as the ‘Act’). 2. At the outset, the ld. AR submitted that there is a delay of 59 days in filing the instant appeal. The assessee has submitted an application for condonation of delay citing valid and proper reasons. After considering the averments made in the application, we condone the delay

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

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

condone the delay and admit the appeal for adjudication. ITA No.: 343/PAT/2025 Assessment Year: 2014-15 Sanjay Kumar. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. The Appellate order of the National Faceless Appeals Centre (NFAC)- Delhi. Is bad and erroneous both on facts and in law. 2. The order

M/S BIHAR STATE WAREHOUSING CORPN. LTD.,PATNA vs. ACIT, CIRCLE-2, PATNA, PATNA

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

Bench: Sri Manish Borad & Sri Sonjoy Sarma

condone the delay and admit the appeal for adjudication. 3. The assessee is in appeal before this Tribunal raising the following grounds: “1. For that the Commissioner of Income Tax (Appeals) - 1, ["the CIT(A)] erred on facts and in law in dismissing the appeal filed by the appellant by confirming the assessment order passed by the assistant Commissioner