BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPN.LTD.,PATNA vs. CIT (APPEAL), DELHI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened u/s 148 of the Act after the expiry of 4 years solely on the ground of change of opinion. 9. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer has erred in disallowing

KISHORI CAPITAL MARKETS PVT. LTD.,BBD BAGH (EAST) vs. ITO WARD 2(1), PATNA, LOK NAYAK BHAWAN

In the result, the appeal filed by the assessee is allowed

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

disallowance of Rs. 2,05,14,580/- has been dismissed but allowed the appeal of the assessee by allowing the credit for pre-assessment taxes paid and accordingly, the appeal has been dismissed. Being aggrieved and dissatisfied with the impugned order, the present appeal has been preferred. 1.1. The ld. Counsel for the assessee challenges the impugned order on various

ACIT, CENTRAL CIRCLE-3, PATNA, PATNA vs. SMT. SIPRA GUPTA, PATNA

reopening of\nassessment. The ground no. 1 is allowed.\n4.\nSo far as the deletion of addition on merit is concerned, the Revenue\nhas challenged the deletion made by the learned CIT (A) of\n₹1,21,63,000/- as made by the learned AO on account of cash\ndeposited during the demonetization period.\n4.1. The facts in brief

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopened and the Assessing Officer (“the Ld. AO”) issued a notice u/s 148, in response to ITA No.: 205/PAT/2025 Assessment Year: 2014-15 Bijay Kumar Saraf. which, the assessee did not file any return of income. Since no compliance was made to the notice issued in the course of reassessment proceedings, the Ld. AO disallowed

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

ACIT, CENTRAL CIRCLE-1, PATNA vs. SONAMOTI AGROTECH PVT LTD, PATNA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

disallowance can be made in relation to that assessment year in exercise of powers under section 153A of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur (supra). Besides, as rightly pointed

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopening the assessment for AY 2017-18 being Salary income offered as income from business and profession. After considering all the facts of the case and submission of the assessee, the Ld. AO treated ₹14,82,260/- as salary income received from the employer for AY 2017-18 and rejected the bogus expenses claimed at ₹7,32,030/- since

SHEKHAR NARAYAN,PATNA vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reopening the assessment for AY 2017-18 being Salary income offered as income from business and profession. After considering all the facts of the case and submission of the assessee, the Ld. AO treated ₹14,82,260/- as salary income received from the employer for AY 2017-18 and rejected the bogus expenses claimed at ₹7,32,030/- since

PAVAN KUMAR BHAGAT,SAHARSA vs. ITO, WARD-3(4), SAHARSA, SAHARA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

disallowing and adding Rs.11,65,739 claimed as commission expenses by the appellant, solely on the ground that the said deduction is not allowable in view of violation of provision of section 194G of the Act and section 40(a)(ia) of the Act, without considering the fact that the commission have been paid genuinely and through banking mode

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

disallowed and added to the total income of the appellant as income from other sources. 12. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer, without giving any opportunity, much less sufficient opportunity, has erred in holding that the appellant had sold immovable property for Rs.33,20,000 and taxed the same under

ANIL KUMAR,NALANDA vs. ITO, WARD- 2 (3), BIHARSHARIF

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Dr. Manish Boradi.T.A. No. 361/Pat/2023 Assessment Year: 2014-15 Anil Kumar National Faceless Assessment Centre M/S Raj Trading Company, Nfac, Delhi Harnaut, Nalanda, Patna-803110 Vs Bihar [Pan : Azopc268H] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

reopening of assessment. 6. For that the Ld. CIT(A) has erred in relying on judgments for upholding the initiation of proceedings u/s 147/148 that too without confronting the appellant with the same. 7. For that the Ld. CIT(A) has erred in holding that there has been escapement to the extent of Rs. 1,44,000/- in the original

RAJENDRA AGRAWAL,BIROLI BAZAR vs. ITO WARD 3(1) PURNEA, PURNIA

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.422/Pat/2024 Assessment Year: 2011-12 Rajendra Agrawal.……………….....…..…………………....Appellant New Sipahi Tola, Maranga Road, Bihar – 85301. [Pan: Aqhpa2439E] Vs. Ito, Ward-3(1), Purnia....….…….…............................…..…..... Respondent Appearances By: None 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 30, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 18 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Care Are That The Assessee Is An Individual & Is Engaged In Farming Activities. The Case Of The Assessee Was Reopened

reopened I.T.A. No.422/Pat/2024 Assessment Year: 2011-12 Rajendra Agrawal u/s 147 of the Act for the assessment year 2011-12. The assessee filed his return electronically declaring Rs.44,590/- as income from other sources and Rs.7,94,275/- as agricultural income. The case of the assessee was selected for complete scrutiny and notices u/s 143(2) and 142(1) were

DCIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

reopened u/s 147 of the Act by issuing notice u/s 148 on 28.03.2019 which was complied with by the assessee by filing return of income on 27.01.2019. We note that the AO has even assessed the income on the basis of return of income filed by the assessee u/s 148 (1) of the Act and even the notice was issued