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 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

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

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

2 appended to section 37(1) by Finance Act, 2014 with effect from 1-4-2015 is applicable prospectively from assessment year 2015-16; therefore, corporate social responsibility expenditure incurred by assessee-company on or before 31-3-2014 was to be allowed as deduction under section 37(1)" Copy of judgments is enclosed. 7. That the appellant states that

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

C-15, Vijay Nagar, Near Petrol Pump, Rukanpura, Baily Road, Patna-800014 [PAN:AAGFM0031K] Appearances by: Shri Rupesh Agrawal, CIT, Sr. D.R., appeared on behalf of the Revenue Shri K.M. Mishra, Advocate, appeared on behalf of the assessee Date of concluding the hearing : August 23, 2023 Date of pronouncing the order : October

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel 2

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel 2

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel 2

ACIT, PATNA vs. NEW ERA SOCIAL DEVELOPMENT WELFARE SOCIETY, PATNA

Appeal is treated as allowed for statistical purposes

C of other details assessee has claimed that it is registered under section 12A/12AA vide registration number 32 dated 4th January 1988 in its ITR. But assessee did not submit copy of certificate of registration after giving several opportunities to justify its claim i.e. Details of project and institution run by assessee, for which it has claimed exemption under section

DIVYA PRAKASH,BHOJPUR vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is dismissed

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

c) where any order referred to in this sub-section and passed by the Assessing Officer had been the subject matter of any appeal filed on or before or after the 1st day of June, 1988, the powers of the Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters

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

13. We have duly considered the rival contentions and gone through the record carefully. As far as the first fold of the dispute is concerned, whether addition under section 153A in the absence of any discovery of incriminating material could be made or not is concerned, we are of the view that the Hon’ble Supreme Court has silenced this

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

13. We have duly considered the rival contentions and gone through the record carefully. As far as the first fold of the dispute is concerned, whether addition under section 153A in the absence of any discovery of incriminating material could be made or not is concerned, we are of the view that the Hon’ble Supreme Court has silenced this