JCIT(IN-SITU), CIRCLE-1, PATNA, PATNA vs. TECHNOCULTURE BUILDING CENTRE PRIVATE LIMITED, PATNA

condoning the delay. Since both the appeals have inter-connected issues hence, they are being heard together for simultaneous adjudication. 2. These appeals arise from the order u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”), passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi vide order dated 12.12.2024. 2.1 In this

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

SWARGIYA PROF NAWAL PD. SINGH S SANSTHAN,VAISHALI vs. CPC, BENGALURU

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.348/Pat/2025 Assessment Year: 2018-19 Swargiya Prof Nawal Pd. Singh S Sansthan…………………..………. …………………....Appellant 0 Sahi Colony, Hajipur, Vaishali, Bihar- 844101.. [Pan: Aagts5236E] Vs. Cpc, Bengaluru……..…....…..……………..………………….…..... Respondent Appearances By: Shri Rakesh Kumar, Adv., 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: This Appeal Is Directed By The Assessee Against The Order Dated 03.01.2025 Passed By The Cit, Appeal Addl/Jcit(A)-3, Chennai Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018–19. The Case Was Processed By The Cpc, Which Issued An Intimation Under Section 143(1) Of The Act, Disallowing The Assessee’S Claim Of Exemption Of ₹1,25,99,176, Being 80% Of The Total Expenditure Against Total Receipts Of ₹1,27,78,294. Consequently, The Total Income Was Determined At ₹₹1,27,78,294. I.T.A. No.348/Pat/2025 Swargiya Prof Nawal Pd. Singh S Sansthan 3. Aggrieved By The Above Intimation, The Assessee Preferred An Appeal Before The Cit(A). However, The Cit(A) Dismissed The Appeal Solely On The Ground That It Was Filed After A Delay Of 1,489 Days, Without Considering The Matter On Merits.

section 143(1) of the Act, disallowing the assessee’s claim of exemption of ₹1,25,99,176, being 80% of the total expenditure against total receipts of ₹1,27,78,294. Consequently, the total income was determined at ₹₹1,27,78,294. I.T.A. No.348/Pat/2025 Swargiya Prof Nawal Pd. Singh S Sansthan 3. Aggrieved by the above intimation, the assessee

PAWAPURI RICE MILL PVT. LTD,NALANDA vs. ITO WARD, 2(1), PATNA, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

delay is condoned. 5. Brief facts of the case are that the assessee is a Private Limited Company engaged in the business of Rice Mill Sector. It filed its return of income for the assessment years under consideration. Subsequently the cases were reopened under section 147 of the Act after obtaining approval of the competent authority after recording reasons

PAWAPURI RICE MILL PVT. LTD,NALANDA vs. ITO, WARD-2(1), PATNA, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

delay is condoned. 5. Brief facts of the case are that the assessee is a Private Limited Company engaged in the business of Rice Mill Sector. It filed its return of income for the assessment years under consideration. Subsequently the cases were reopened under section 147 of the Act after obtaining approval of the competent authority after recording reasons

PAWAPURI RICE MILL PVT. LTD,NALANDA vs. ITO, WARD-2(1), PATNA, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 634/Pat/2024 Assessment Year: 2013-2014 & I.T.A. No. 635/Pat/2024 Assessment Year: 2014-2015 & I.T.A. No. 636/Pat/2024 Assessment Year: 2015-2016 Pawapuri Rice Mill Pvt. Limited,……..……..Appellant Pokhapur, Pawapuri, P.S. Giriyak, Nalanda-803115, Bihar [Pan:Aagcp6179C] -Vs.- Income Tax Officer,…………………….………...Respondent Ward-2(1), Patna, Bihar Appearances By: No N E, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 05, 2025 Date Of Pronouncing The Order: May 27, 2025 O R D E R Per Duvvuru Rl Reddy, Vice-(Kz):- The Present Three Appeals Bearing Ita Nos. 634/Pat/2024, 635/Pat/2024 & 636/Pat/2024 Are Directed At The Instance Of Assessee Against The Orders Of Ld. Commissioner Of Income Tax

delay is condoned. 5. Brief facts of the case are that the assessee is a Private Limited Company engaged in the business of Rice Mill Sector. It filed its return of income for the assessment years under consideration. Subsequently the cases were reopened under section 147 of the Act after obtaining approval of the competent authority after recording reasons

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

section 143(1). In other words, the return of the assessee was processed by a computer and whereby it made an adjustment of Rs.15,05,78,356/- under the head “income from other sources”. This intimation was uploaded on Income Tax e- Portal on 12.07.2018. The assessee was required to respond to this intimation. When he failed to respond

BINDESHWARI LAL MAHTO,KATIHAR vs. NFAC, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

78,000 as unexplained income under section 69A of the Act merely on the ground that the notices issued were not complied with. 5. For that the learned Commissioner of Income Tax (Appeal) has erred in dismissing the appeal in liminie merely on the ground that the appeal was filed belated that the explanation as regards delay were not acceptable

DINESH KUMAR,PATNA vs. ITO WARD (5), PATNA

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.427/Pat/2024 Assessment Year: 2016-17 Dinesh Kumar……………………….....…..…………………....Appellant C/O Bhurendra Prasad, Near B D Public School, Buddha Colony, Patna – 800001. [Pan: Bxbpk1456M] Vs. Ito, Ward-5, Patna…………. ….…….…............................…..…..... Respondent Appearances By: Shri Shailendra Sinha, Ar Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 27, 2025 Date Of Pronouncing The Order : January 28, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 31.03.2024 Of The Commissioner Of Income Tax (Appeals), Jaipur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2016-17 By Showing Total Income Of Rs.2,71,810/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass Followed By Notices Issued U/S 143(2) & 142(1) Of The Act. The Assessing Officer Asked The Assessee To Produce Books Of Accounts, Ledger, Cash Book Etc. Before Him But The Assessee Did Not Comply. Accordingly, The Assessing Officer After Verification Of Return Of Income Found That The Assessee Had Filed Balance Sheet Showing Gross Total Income Of Rs.36,00,712/- & The Assessee Incurred Miscellaneous

78,900/-. Therefore, the net profit comes to Rs.4,21,812/-. The Assessing Officer also found that on perusal of Form 26AS, the gross receipts was civil contract work under TDS section 194, Rs.4025927/- on which TDS was deducted. As the assessee was shown gross receipts of Rs.3600712/-, therefore, the difference of Rs.425212/- was treated as income from business

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

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

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

PRAKASH GUPTA,GOPALGANJ vs. THE INCOME TAX OFFICER, WARD- 2 (4), SIWAN

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

condonation of delay, however a submission stated to be an affidavit I.T.A. No.: 206/PAT/2025 Assessment Year: 2017-18 Prakash Gupta. has been filed in which it is stated that during the demonetisation period, total sum of ₹ 10,69,000/- was deposited into the SBI account and the cash deposited was not the personal income but represented transactions conducted by customers

KHURSHID ASHRAF,PATNA vs. ITO WARD-4 (5), PATNA

The appeal of the assessee is allowed

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

condone the delay and decide the appeal on merit. 3. The assessee has taken eleven grounds of appeal, which are descriptive in nature. Before adverting to the specific grounds of appeal, we deem it appropriate to take note of facts and circumstances of the case. 4. Brief facts of the case are that the assessee has filed his return

ITO, WARD-3(1), GAYA vs. SHRI GAURI TEXTILES INDUSTRIES, GAYA

In the result, the appeal filed by the revenue is dismissed and corresponding cross-objection filed by the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.118/Pat/2020 Assessment Year: 2017-18 Ito, Ward-3(1), Gaya…………….………………………………….…..……Appellant Vs. Shri Gauri Textile Industries, Gaya…………...........……........……...…..…..Respondent Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] C.O. No.5/Pat/2021 (Arising Out Of I.T.A. No.118/Pat/2020) Assessment Year: 2017-18 Shri Gauri Textile Industries, Gaya ……………….………………..….…..Cross-Objector Buniadgaj Manpur, Gaya, Bihar-823003. [Pan: Aalfs4803J] Vs. Ito, Ward-3(1), Gaya………….................................……........……....…..…..Respondent Appearances By: Shri Manish Rastogi, Advocate, Appeared On Behalf Of The Assessee. Shri Ashok Kumar, Cit, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : January 30, 2025 Date Of Pronouncing The Order : March 18, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal Against The Order Dated 31.08.2020 By The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As The ‘Cit(A)’] & The Assessee Has Filed The Corresponding Cross-Objection Relating To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That A Survey Was Conducted On 07.02.2017 In The Case Of The Assessee, A Partnership Firm Engaged In Trading Business Of Cotton Yarn & Hosiery Yarn. During The Survey, It Was Observed That The Assessee Has Made Substantial Deposits In Various Bank Accounts Linked With The Firm. However, The Assessee Disclosed

78,07,011/- and after deducting Rs.82,08,143/- which the closing stock as per audited books of account arrived at a difference of Rs.95,98,868/-. Based on the above set of facts the correct and proper manner of understanding the difference in stock as per books and as physically found was to factor in the purchases and sales