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

disallowances made by the A.O. u/s 40A(3) and section 40(a)(ia) are hereby deleted and income is estimated at the end of discussion of all other grounds of appeal”. 6. The ld. Sr. D.R. took us through the assessment order. He submitted that perusal of section 40A(3) would indicate that any assessee incurring expenditure exceeding Rs.20

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

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.30,52,570/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2013-14 corresponding to Assessment Year 2014-15, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted

SIS LIMITED,PATNA vs. ACIT, DELHI

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

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

disallowance under section 36(1)(va) of the Act. 7. That on the facts and circumstances of the case, the CIT(A) has erred

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

section 194C or 194(I). To our mind, the ld. Assessing Officer has not demonstrated the actual defaults committed by the assessee and, therefore, under such circumstances, he cannot disallow under a general narration. We allow this ground of appeal and delete the disallowance. 14. In Grounds No. 6, 7

GUPTA JI BROTHERS RICE PRIVATE LIMITED,DALMIA NAGAR vs. DCIT CIRCLE-3, GAYA

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

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

disallowance of Rs. 74,025/- are too exacting for allowability for expenses under Section 37(1) of the Act. We accordingly direct that the quantum of said expenditure added back, should be deleted. 3.1 Regarding the addition of Rs. 7

BIHAR COMBINED ENTRANCE COMPETITIVE EXAMINATION BOARD,PATNA vs. ACIT(EXEMPTIONS CIRCLE), PATNA

In the result, both the appeals of the assessee are allowed

section 10(23C) as stated above. Therefore, the disallowance made by the ld. Assessing Officer will not create any tax liability of the assessee. In view of this, the impugned order of the ld. CIT(Appeals) is set aside and the additions made by the lower authorities are deleted. 7

BIHAR COMBINED ENTRANCE COMPETITIVE EXAMINATION BOARD,PATNA vs. ACIT(EXEMPTIONS CIRCLE), PATNA

In the result, both the appeals of the assessee are allowed

section 10(23C) as stated above. Therefore, the disallowance made by the ld. Assessing Officer will not create any tax liability of the assessee. In view of this, the impugned order of the ld. CIT(Appeals) is set aside and the additions made by the lower authorities are deleted. 7

WASEEM ALAM,WEST CHAMPARAN vs. ITO, NATIONAL E ASSESSMENT CENTRE, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.17/Pat/2025 Assessment Year: 2018-19 Waseem Alam…...………………….....…..…………………....Appellant Bhawanipur Kursi Barawa, Sikta, West Champaran, Bihar-845307. [Pan: Alopa0369B] Vs. Ito, Nfac, Delhi…………..……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 17, 2025 Date Of Pronouncing The Order : July 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.9,68,550. The Return Was Processed Under Section 143(1) Of The Act. Subsequently, The Case Was Selected For Limited Scrutiny Under The E- Assessment Scheme, With The Specific Issue Of Verification Of Large Deduction Claimed Under Section 57 Of The Act. Notice Under Section 143(2) & Subsequently Under Section 142(1) Was Issued To The Assessee. Although The Assessee Uploaded Certain Documents Electronically In Response, The Details Were Found To Be Incomplete. The

disallowed solely on the ground that the assessee failed to furnish necessary evidence to establish that the expenses were incurred wholly and exclusively for the purpose of earning such income. It is also evident that the assessee had made partial compliance with the notices issued under Section 142(1) and has now pleaded for an opportunity to produce the relevant

RAVI LOCHAN SINGH,PATNA vs. ITO, WARD-5(1), PATNA

In the result, both the appeals of the assessee are allowed

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

7. In assessment year 2013-14, the first payment is of Rs.6,07,335/-. It was paid to nine concerns and claimed Assessment Years: 2012-2013 & 2013-2014 Ravi Lochan Singh under the head “commission”. This payment has been disallowed to the assessee on the ground that the assessee failed to deduct the TDS under section

RAVI LOCHAN SINGH,PATNA vs. ITO, WARD-5(1), PATNA

In the result, both the appeals of the assessee are allowed

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

7. In assessment year 2013-14, the first payment is of Rs.6,07,335/-. It was paid to nine concerns and claimed Assessment Years: 2012-2013 & 2013-2014 Ravi Lochan Singh under the head “commission”. This payment has been disallowed to the assessee on the ground that the assessee failed to deduct the TDS under section

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

7. Ld. Counsel for the assessee firstly made reference to the paper book containing 623 pages, which contains the notice under section 142(1) of the Act issued by the ld. Assessing Officer for the impugned assessment years from 2017-18 to 2021-22 under appeals, various replies Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited given

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

7. Ld. Counsel for the assessee firstly made reference to the paper book containing 623 pages, which contains the notice under section 142(1) of the Act issued by the ld. Assessing Officer for the impugned assessment years from 2017-18 to 2021-22 under appeals, various replies Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited given

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

7. Ld. Counsel for the assessee firstly made reference to the paper book containing 623 pages, which contains the notice under section 142(1) of the Act issued by the ld. Assessing Officer for the impugned assessment years from 2017-18 to 2021-22 under appeals, various replies Assessment Years: 2017-2018to 2021-2022 Gandhipati Construction Private Limited given