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]

143(2) of the Act which were also referred by the Ld. CIT(A). Considering the ratio laid down in the above decisions, we hold that the Ld. CIT(A) has rightly allowed the appeal of the assessee on legal issue. Accordingly we uphold the order of Ld. CIT(A) by dismissing the appeal of the revenue. 18. Insofar

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]

143(2) of the Act which were also referred by the Ld. CIT(A). Considering the ratio laid down in the above decisions, we hold that the Ld. CIT(A) has rightly allowed the appeal of the assessee on legal issue. Accordingly we uphold the order of Ld. CIT(A) by dismissing the appeal of the revenue. 18. Insofar

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]

143(2) of the Act which were also referred by the Ld. CIT(A). Considering the ratio laid down in the above decisions, we hold that the Ld. CIT(A) has rightly allowed the appeal of the assessee on legal issue. Accordingly we uphold the order of Ld. CIT(A) by dismissing the appeal of the revenue. 18. Insofar

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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. 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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. 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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. 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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. 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

Section 143(3) of the Act for Assessment Year 2014-15 by the Ld. assessing officer, viz. the Assistant Commissioner of Income Tax, Circle 2, Patna and that an assessment concluded u/s 143(3) of the Act cannot be assessed solely on the ground of change of opinion. I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024

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

2) and 142. Questionnaires were issued to which the assessee company had responded by furnishing details and documents about the deduction under section 80-IA and finally the then Assessing Officer made the assessment and detail scrutiny order under section 143(3) was passed 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

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

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

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2010-2011 Manish Finlease Pvt Ltd., Vs. Ito, Ward 2(1), Patna Chandi House Exhibition Road, Patna Pan/Gir No.Aaccm 6252 B (Appellant) .. ( Respondent) Assessee By : Shri A.K.Rastogi & Rakesh Kumar, Ars Revenue By : Shri Indrajeet Singh, Dr Date Of Hearing : 20/06/ 2019 Date Of Pronouncement : 09/08/ 2019 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-1, Patna Dated 27.9.2018 For The Assessment Year 2010-2011. 2. The Appeal Filed By The Assessee Is Delayed By 51 Days. The Assessee Has Filed Application For Condonation Of Delay Stating The Reasons For Not Filing The Appeal In Time Before The Tribunal. After Hearing The Submissions Of The Parties, We Are Satisfied That The Assessee Had A Bonafide Reason For Not Filing The Appeal In Time. Therefore, We Condone The Delay & Proceed To Decide The Appeal Of The Assessee On Merits.

143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment yeari, unless any P a g e 7 | 71 Assessment Year : 2010 -2011 income chargeable to tax has escaped assessment for such assessment year by reason

RAJ CONSTRUCTION,KATIHAR vs. ACIT, CIRCLE-1(1), BHAGALPUR

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

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am Asst. Commissioner Of Income Tax, Raj Construction Circle – 1(1), C/O Mahadev Ghosh, Bhagalpur, Advocate Vs. Bf-199, Salt Lake City, R.N. Plaza, R.B.S.S Kolkata-700064 Sahay Road, Bhagalpur, Bihar- 812001 (Appellant) (Respondent) Pan No. Aajfr6306F Assessee By : Shri Mahadev Ghosh, Ar Revenue By : Shri Ashwani Kumar, Dr Date Of Hearing: 20.08.2024 Date Of Pronouncement: 29.08.2024

Section 144/ 143(3) of the Income-tax Act, 1961 (the Act) dated 14th December, 2017. 02. Registry is informed that the appeal is time barred for 5 days. Application for condonation of delay has been filed. The delay in filing of appeal is attributable to the person Raj Construction; A.Y. 2015-16 looking after the appellate work. An affidavit