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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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

74,78,32,931/-. The Ld. CIT(A) confirmed the addition on account of disallowance u/s 80-IA of the Act by relying upon I.T.A. Nos.: 330, 331, 332, 333, 334 & 335/PAT/2024 AYs: 2012-13, 2013-14, 2014-15, 2014-15, 2017-18 & 2018-19 Bihar State Road Development Corporation Limited (BSRDCL). the decisions of Hon'ble Supreme Court

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)

section 36(1)(va) of the Income Tax Act, 1961 ('the Act'). 3. That on the facts and circumstances of the case, the CIT(A) has erred, both on facts and in law in not appreciating that the amount of Rs. 3,55,74,642/- that the appellant had taken active steps to deposit the employee contribution before

RANI DEVI,PATNA vs. INCOME TAX OFFICER, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

74,289/- ) and the difference of income as determined under section 44AD and net profit shown by the assessee, which comes to Rs.28,91,375/- was added to the total income of the assessee. The ld. Assessing Officer disallowed

RUSHATAM KHAN,PURNEA vs. ACIT, CIRCLE-3, PURNEA

In the result, both the appeals of the assessee for AYs 2013-

Bench: Sri Manish Borad & Sri Sonjoy Sarma

74,520/- of M/s Khan Traders discussed, disallowed and added as per Para D of the order passed by the Ld. assessing officer in passing order based on adhoc, presumption, surmise, inference and ignoring facts and circumstances of the case. 6. For that the CIT (Appeal) erred in passing ex-parte order confirming disallowance & additions

RUSHATAM KHAN,PURNEA vs. ACIT, CIRCLE-3, PURNEA

In the result, both the appeals of the assessee for AYs 2013-

Bench: Sri Manish Borad & Sri Sonjoy Sarma

74,520/- of M/s Khan Traders discussed, disallowed and added as per Para D of the order passed by the Ld. assessing officer in passing order based on adhoc, presumption, surmise, inference and ignoring facts and circumstances of the case. 6. For that the CIT (Appeal) erred in passing ex-parte order confirming disallowance & additions

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

disallowance of the provisional expenditure as per para 11 of the assessment order at ₹44,70,128/- were made and the total income was assessed at ₹176,92,74,630/-. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered in detail the provisions of section

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

disallowance of Rs.76,191/- @20% out of expenses claimed under various heads. (8) For that the sustenance of addition/disallowances of Rs.7,26,001/-, Rs. 10,56,328/-, Rs.32,71,379/-, Rs.3,00,000/- and Rs.76.191/- by the Ld. CIT(A) are wrong, illegal and unjustified on the facts and in the circumstances of the appellant's case. (9) For that

SEEMA SRIVASTAVA,PATNA vs. ITO,DC/AC-6, PATNA, PATNA

In the result, the appeal is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

sections. 9. For that the appellant reserves its right to furnish detailed written submission along with documents and evidences on or before date of hearing. 10. For that the appellant may be given opportunity of personal hearing physically/virtually at the time of hearing of the appeal. 11. For that the whole order is bad in fact

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.

74 ITR 594 (Punj.&Har.). 2.12 The jurisdictional High Court in the case ofBhimrajPannaLal v. CIT [1957] 32JTR £89 (Pat.) held that the words 'reason to believe' do not mean 'reason to suspect'. Section 147 does not give unfettered discretion to the income-tax authorities. The belief entertained by the authorities must not be arbitrary or irrational. It must

M/S BIHAR STATE WAREHOUSING CORPN. LTD.,PATNA vs. CIT (A), NFAC, DELHI, DELHI

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

Bench: the Commissioner of Income Tax (Appeals)-1 was disposed of by an Order ITBA/NFAC/S/250/2022- 23/1047736388(1) dated 30-11-2022 passed by Commissioner of Income Tax M/s Bihar State Warehousing Corpn. Ltd.

74,97,125/-, as against assessed income of Rs. 3,45,06,732/-, under section 147 r.w.s 143(3) of the Income Tax Act, 1961. ("the Act"). 2. For that the CIT(A) erred on facts and in law in confirming the addition of Rs. 29,90,393/-, which is wrong, illegal and unjustified. 3. The Appellant prays that

M/S BIHAR STATE WAREHOUSING CORPN. LTD.,PATNA vs. CIT (A), NFAC, DELHI, DELHI

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

Bench: the Commissioner of Income Tax (Appeals)-1 was disposed of by an Order ITBA/NFAC/S/250/2022- 23/1047736388(1) dated 30-11-2022 passed by Commissioner of Income Tax M/s Bihar State Warehousing Corpn. Ltd.

74,97,125/-, as against assessed income of Rs. 3,45,06,732/-, under section 147 r.w.s 143(3) of the Income Tax Act, 1961. ("the Act"). 2. For that the CIT(A) erred on facts and in law in confirming the addition of Rs. 29,90,393/-, which is wrong, illegal and unjustified. 3. The Appellant prays that

ACIT, CIRCLE-1, PATNA vs. BIHAR KSHETRIYA GRAMIN BANK, MUNGER

In the result, the appeal of the revenue is dismissed

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

74,508/- but bills for an amount of Rs. 1,36,11,905/- could be filed and remaining amount of Rs. 1,62,603/- were not able to filed by the assessee. Similarly, in relation to furniture & fixtures, bills were not produced for an amount of Rs. 17,85,223/-. Accordingly, the ld. AO reduced the depreciation claimed

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 271(1)(b) of the Act was also filed. It was stated that the Ld. CIT(A) sustained part of the disallowance even though the assessee was not liable for deduction of any TDS as the assessee is trading in sugar and the liability for deduction did not arise as only if the aggregate payment