ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. AJIT KUMAR, BETTIAH

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

Bench: Shri George Mathan & Shri Rakesh Mishra

section 40A(3) of the Act. A reference was made to page 11 of the assessment order and page 26 of the Ld. CIT(A)’s order. The written submission filed in this regard are as under: “1. The assessee at the time of hearing before CIT(A) had submitted in respect of the disallowance

SHASHI KRISHNA EDUCATIONAL AVAM WELFARE SOCIETY,PATNA vs. AO, PATNA

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

disallowed income, the entire income should have\nbeen charged to tax. The omission resulted in under assessment of\nincome of Rs. 70.82 crore involving short levy of tax of Rs.24.07 crore.\nIn fact, the ITD itself, in case of another assessee (AY 2014-15), in an\nassessment completed under section 143(3) in December 2016,\ndenied exemption under section 11

I.T.O. vs. M/S KUMAR CONSTRUCLTION,

In the result, the appeal of the Revenue is partly allowed

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

11. A perusal of the impugned order would reveal that ld. CIT(Appeals) has rejected the book result and estimated net profit rate at 8% of the gross receipts, which worked out to a profit of Rs.77,68,919/-. The Revenue is aggrieved with this exercise and emphasized that ld. Assessing Officer has made specific disallowances under sections 40A(3

PUNRASAR JUTE PARK LIMITED,PURNEA vs. CIT, PURNEA

In the result, the appeal of the assessee is allowed

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

11. As seen from the above, the first proviso to sec. 147 of the Act prohibits any action under section 147 after the expiry of four years from the end of the relevant assessment year, except in circumstances specified therein. One of such circumstances is that the income chargeable to tax should have escaped assessment by reason of the failure

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

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

disallowing Rs.66,47,34,169/- on the account of deduction claimed u/s 80IA of the Act due to interest income from Fixed Deposit, Saving Account and other income. 11. For that the appellant shall place any other point/points at the time of hearing of the appeal.” II. ITA No. 331/PAT/2024; AY 2013-14: “1. For that the grounds of appeal

ACIT, CENTRAL CIRCLE-2, 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]

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

KUMAR ARUNOSAYA,PATNA vs. A.O., CIRCLE-6, 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]

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

KUMAR ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], 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]

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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]

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

ACIT, 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]

Section 68 cannot be invoked. Accordingly we set aside the order of Ld. CIT(A) and direct the AO to delete the addition. Accordingly the appeal of the assessee is allowed. ITA No. 98/Pat/2021 for AY 2016-17 23. The issue raised in ground no. 1 and 2 by the revenue is against the order of Ld. CIT(A) allowing

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

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

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

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

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

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

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

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves