VAISHAL PATLIPUTRA DUGDH UTPADAK SAHKARI SANGH LIMITED,PATNA vs. ASSESSMENT UNIT, PATNA

In the result, the ITA Nos

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

84 delay 431/Patna/2025 296 days 432/Patna/2025 175 days 433/Patna/2025 175 days 434/Patna/2025 175 days 3. Separate condonation of delay petitions has been filed explaining the reasons for delay. After considering the reasons stated therein, we are satisfied that sufficient cause exists. Accordingly, the delays are condoned, and the appeals are admitted for adjudication. 4. First we take ITA No. 429/Patna/2025

VAISHAL PATLIPUTRA DUGDH UTPADAK SAHKARI SANGH LIMITED,PATNA vs. ASSESSMENT UNIT, PATNA

In the result, the ITA Nos

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

84 delay 431/Patna/2025 296 days 432/Patna/2025 175 days 433/Patna/2025 175 days 434/Patna/2025 175 days 3. Separate condonation of delay petitions has been filed explaining the reasons for delay. After considering the reasons stated therein, we are satisfied that sufficient cause exists. Accordingly, the delays are condoned, and the appeals are admitted for adjudication. 4. First we take ITA No. 429/Patna/2025

VAISHAL PATLIPUTRA DUGDH UTPADAK SAHKARI SANGH LIMITED,PATNA vs. ASSESSMENT UNIT, PATNA

In the result, the ITA Nos

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

84 delay 431/Patna/2025 296 days 432/Patna/2025 175 days 433/Patna/2025 175 days 434/Patna/2025 175 days 3. Separate condonation of delay petitions has been filed explaining the reasons for delay. After considering the reasons stated therein, we are satisfied that sufficient cause exists. Accordingly, the delays are condoned, and the appeals are admitted for adjudication. 4. First we take ITA No. 429/Patna/2025

SUNITA DEVI,PATNA vs. ITO, WARD- 6 (1), PATNA

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

Bench: this Hon'ble Tribunal. 7. That the delay in filing the appeal was not intentional, nor due to any negligence or laxity on my part, but due to bona fide reasons beyond my control: 8. That I submit that substantial justice should not be denied merely due to procedural delay and that the appeal may be decided on merits. 9. That I humbly request this Hon'ble Tribunal to condone the delay and allow my

delay is condoned and the appeal is admitted for adjudication. 2. The sole ground of appeal raised by the assessee is reproduced as under: “1. Addition of Rs. 1,26,24,890/- in income is bad in law.” 3. Brief facts of the case are that the assessee is an individual and is the proprietor of M/s Balajee Polly Packaging

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

ALMAHAD TRUST ,PATNA vs. ITO EXEMPTION, WARD-1, PATNA , PATNA

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

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

condone the delay and the appeal is taking for adjudication. 5. Briefly stated that facts of the case are that as per e-filing portal the assessee has deposited cash of Rs. 21,84,076/- in A/c No. 032404010003154 to J & K Bank based on the information. A notice u/s 148 of the Act was issued to the assessee

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

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

LAL BABU PRASAD,SIWAN vs. ACIT, CIRCLE-2, MUZAFFARPUR

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

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

84, Dindayal Nagar, Siwan - 841226 [PAN: AJGPP3456L] ..…...…………….... Appellant vs. Asst. Commissioner of Income Tax, Circle 2(1), Muzaffarpur ..…...…………….... Respondent Appearances by: Assessee represented by : Shri Rahul Gabhawala, CA Department represented by : Shri Manab Adak, JCIT Date of concluding the hearing : 14.01.2026 Date of pronouncing the order : 16.01.2026 O R D E R PER SONJOY SARMA, JUDICIAL MEMBER This appeal arises

PANKAJ JAISWAL,KHAGARIA vs. ITO, WARD-2(10, BEGUSARAI

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

Bench: Shri P. M. Jagtap, Hon’Ble Vice-(Kz) I.T.A. No.80/Pat/2020 Assessment Year: 2011-12 Pankaj Jaiswal.…………………………………….……………………………………..………..Appellant Kachari Road, In Front Of Ib Ward No.15, Khagaria-851204.. [Pan :Ahypj1958M] Vs. Ito, Ward-2(1), Begusarai..…....…………………………………………………..……Respondent

delay is condoned. 3. The assessee in this present case is an individual who filed his return of income for the year under consideration on 29.08.2011 declaring a total income of Rs.1,94,130/-. As per the information available with the A.O, the assessee haf maintained two bank accounts with ICICI Bank, one with Khagaria Branch and the other with

PARSAMBI DESIGN & CONSTRUCTION PRIVATE LIMITED,PATNA vs. ITO, WARD-2 (2), PATNA

In the result, the Stay Application is dismissed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumars.A. No. 6/Pat/2024 (In Ita No. 403/Pat/2024) Assessment Year: 2015-2016 & I.T.A. No. 403/Pat/2024 Assessment Year: 2015-2016 Parsambi Design & Construction Private Limited,……………….………….……….Appellant G-1, Prasambi Saryug Vihar Apartment, Gosaitola, Patna-800013, Bihar [Pan:Aadcp2202M] -Vs.- Income Tax Officer,…..………………………..Respondent Ward-2(2), Patna, District-Patna, Bihar Appearances By: Shri Narendra Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Sushil Kumar Mishra, Jcit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 21, 2024 Date Of Pronouncing The Order: May 21, 2024 O R D E R

delay, we deem it appropriate to condone it after going through the explanation of the assessee. 3. In the Stay Application, the assessee has sought ad-interim stay of the outstanding demand amounting to Rs.4,65,981/-. 4. With the assistance of ld. Representatives, we have gone through the record carefully. While considering the Stay Application, we find that