GANADHIPATI CONSTRUCTION PVT LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

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

seizure action dated 29.10.2020 in the case of assessee company. This was all the more necessary in the light of the fact that regular books of accounts were neither found during the course of search action nor properly produced by the assessee company during post-search enquiries. Explanation-2enjoins upon the Assessing Officer to conduct necessary enquiries and verifications before

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

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

seizure action dated 29.10.2020 in the case of assessee company. This was all the more necessary in the light of the fact that regular books of accounts were neither found during the course of search action nor properly produced by the assessee company during post-search enquiries. Explanation-2enjoins upon the Assessing Officer to conduct necessary enquiries and verifications before

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

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

seizure action dated 29.10.2020 in the case of assessee company. This was all the more necessary in the light of the fact that regular books of accounts were neither found during the course of search action nor properly produced by the assessee company during post-search enquiries. Explanation-2enjoins upon the Assessing Officer to conduct necessary enquiries and verifications before

PIYUSH & ASSOCIATES PRIVATE LIMITED,PATNA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

ACIT, CENTRAL CIRCLE-1, PATNA vs. PROMINENT FINANCIAL ADVISORY PVT LTD, KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

ACIT, CENTRAL CIRCLE-1, PATNA vs. PROMINENT FINANCIAL ADVISORY PVT LTD, KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

ACIT, CENTRAL CIRCLE-1, PATNA vs. PIYUSH & ASSOCIATES PRIVATE LIMITED, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

disallowance of interest expenditure at ₹4,64,520/- and ₹6,81,334/- for A.Y. 2015-16 and 2016-17, respectively. 14. We have heard the rival contentions and perused the records placed before us. We observe that the ld. AO while carrying out the assessment proceedings for the impugned assessment year, based on information gathered during search and seizure

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

disallowing expenses of Rs.732030/-. The appellant is working as a faculty in M/s. Mentors Eduserv at Patna. The search and seizure

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

disallowing expenses of Rs.732030/-. The appellant is working as a faculty in M/s. Mentors Eduserv at Patna. The search and seizure

KAMLA DEVI JAYDAYAL JAIN PRIVATE LIMITED,MUZAFFARPUR vs. ASSISTANT COMMISIONER OF INCOME TAX, MUZAFFARPUR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

disallowances were made on the basis of statement in which it was claimed that the expenses were inflated for two years. Since the search and seizure

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

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

seizure operations u/s 132(1) of the Income Tax Act, 1961 was conducted on 10.01.2014 in Sona group eases of Patna. The appellant M/s Sona Moti Agrotcch Pvt. Ltd. is related to Sona Group of cases and also subjected to search. Apparently as can be seen from the assessment order the AO has not referred to any material cither found

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

seizure operation under section 132(1) and survey operation under section 133A of the Income Tax Act were conducted at various premises of Subhash Prasad Yadav Group of cases on 23.02.2018. In order to give a logical end to the search proceeding, the case of the assessee was centralized with ACIT, Central Circle-3, Patna and it has not been

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

seizure operation under section 132(1) and survey operation under section 133A of the Income Tax Act were conducted at various premises of Subhash Prasad Yadav Group of cases on 23.02.2018. In order to give a logical end to the search proceeding, the case of the assessee was centralized with ACIT, Central Circle-3, Patna and it has not been

ACIT, CENTRAL CIRCLE-3, PATNA, PATNA vs. RADHA MOHAN ROY, PURNEA

In the result, the appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Acit, Central Circle-3, Patna Radha Mohan Roy, 6Th Floor, Room No.602 Mohan Nivas At Chopra Bazar, Central Revenue Building Ramnagar, Farshi Banmanki, Vs. (Annexe), Beer Chand Patel Purnea, Bihari-854102 Marg, Patna, Bihar-800001 (Appellant) (Respondent) Pan No. Buzpr3181H Co No. 03/Pat/2025 (Arising In Ita No. 264/Pat/2025 For A.Y. 2019-20) Acit, Central Circle-3, Patna Radha Mohan Roy, 6Th Floor, Room No.602 Mohan Nivas At Chopra Bazar, Central Revenue Building Ramnagar, Farshi Banmanki, Vs. (Annexe), Beer Chand Patel Purnea, Bihari-854102 Marg, Patna, Bihar-800001 (Applicant) (Respondent) Assessee By : S/Shri A.K. Rastogi, Rakesh Kumar, Ars Revenue By : Shri Md. Ah Chowdhary, Dr Date Of Hearing: 26.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Rajesh Kumar, Am:

disallowances were not sustainable in the eyes of law. 6. After hearing the rival contentions and perusing the materials available on record, we find that undisputedly, the instant assessment year is an unabated assessment on the date of search as there was no pending proceedings against the assessee u/s 143(3) of the Act and the time limit for issuing

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

seizure operation u/s 132(1) of the Act was conducted on\n19.02.2004 in the case of the assessee as well as his\nassociates/relatives. In this search operation, substantial investments in\nform of movable and immoveable properties were discovered which was\nalleged to have been unaccounted income of the assessee. The\ninvestigation revealed significant undisclosed income from activities\nrelated to examinations

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

In the result, I.T.A. Nos

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.212 To 216/Pat/2023 Assessment Years: 1998-99 & 2001-02 To 2004-05 Kumar Suman Singh………………………..……………………………...……Appellant F-62, P.C. Colony, Kankarbagh, Patna, Bihar – 800020. [Pan: Aihps1976L] Vs. Acit, Central Circle-2, Patna…………....….…......……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit – Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : January 09, 2025 Order Per Bench: These Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 1998-99 & 2001-02 To 2004-05 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Mostly Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That There Is A Delay Of 132 Days In Filing The Instant Appeals. The Assessee Has Submitted Applications For Condonation Of Delay Citing Reasonable Grounds. After Considering The Averments Made In The Applications, We Condone The Delay.

seizure operation u/s 132(1) of the Act was conducted on 19.02.2004 in the case of the assessee as well as his associates/relatives. In this search operation, substantial investments in form of movable and immoveable properties were discovered which was alleged to have been unaccounted income of the assessee. The investigation revealed significant undisclosed income from activities related to examinations