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

Appeal is treated as allowed for statistical purposes

disallowed by the undersigned. After due consideration of facts & circumstances and verification of documents available in this office, the income of the assessee AOP/BOI is computed u/s 144 i.e. Best Judgment Assessment as Rs. 5,80,39,300/-.” 1.2 Aggrieved with this action, the assessee approached the Ld. CIT(A), who has in principle supported the action

ARANYA CLEARERS,GAYA vs. ITO, WARD-3(1), GAYA

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal

8. On appeal, the ld. CIT(Appeals) has scaled down this disallowance to 15%. On due consideration of the above details, we are of the view that there is no dispute that whenever a disallowance is to be worked out on the basis of an estimation, then some guesswork will always be involved. In the present case nature of expenses

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

8. That the appellant states that the Id assessing officer disallowing claim of the appellant under Section 80-IA of the Act, has all together ignored the fact that the appellant is wholly owned State Government company and is engaged in construction and maintenance of roads in the State of Bihar and I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

section 145(3) is not applicable. The income estimated in the manner provided u/s 144 of the I. T Act, 1961 @ 8% is arbitrary and unjust. The addition as made is fit to be deleted. (iii) For that in the facts and circumstances of the case, the disallowances of bonafide and legitimate deduction available to the assessee

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

section 145(3) is not applicable. The income estimated in the manner provided u/s 144 of the I. T Act, 1961 @ 8% is arbitrary and unjust. The addition as made is fit to be deleted. (iii) For that in the facts and circumstances of the case, the disallowances of bonafide and legitimate deduction available to the assessee

SOCIETY FOR ADVANCEMENT OF VILLAGE ECONOMY,GAYA vs. ACIT(EXEMPTION) CIRCLE, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

13(8) were also not applicable. It be so held now by granting exemption u/s. 11 of the Act as claimed. 5. FOR THAT Ld. CIT (A) erred in law and on facts in not appreciating the fact that the appellant was not engaged in any commercial/business activity but was carrying out charitable activity in accordance with its objects

ASHOK KUMAR,BHOJPUR vs. ITO, WARD-1, ARA

In the result, the appeal of the assessee is partly allowed as indicated above

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

8 Assessment Year: 2010-2011 Ashok Kumar 9 Assessment Year: 2010-2011 Ashok Kumar 9. The first finding of the ld. Assessing Officer is qua the estimation of gross profit, which we have considered while dealing with Ground No. 3 of the assessee’s grounds of appeal. Applying the same logic on unrecorded purchases, the ld. Assessing Officer has worked

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 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 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

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

8. On the other hand, ld. D.R. vehemently argued supporting the order of ld. CIT(Appeals). 9. We have heard the rival contentions and perused the material placed before us. Validity of notice under section 148 and reopening proceedings under section 147 of the Act are in challenge before us. The crux of the submissions of ld. Counsel