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 80-IA of the Act. 8. That the appellant states that the Id assessing officer disallowing claim of the appellant

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 80-IA of the Act. 8. That the appellant states that the Id assessing officer disallowing claim of the appellant

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 80-IA of the Act. 8. That the appellant states that the Id assessing officer disallowing claim of the appellant

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 80-IA of the Act. 8. That the appellant states that the Id assessing officer disallowing claim of the appellant

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

section 80-IA(4)(iv) claimed and allowed on generation and sale of steam by assessee was to be disallowed

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

80,000/-. This is not payment. This is withdrawal by an employee of the assessee. The payment might be to different persons and may not exceed Rs.20,000/-. Similarly the other disallowance is made under section

ACIT, CENTRAL CIRCLE-3, PATNA, PATNA vs. SMT. SIPRA GUPTA, PATNA

disallowing the exemption of Rs.150000 claimed\nunder section 80 by the appellant on account of accrued interest on NSC payment

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

Appeal is treated as allowed for statistical purposes

80,39,300/-plus other section in ITR is hereby disallowed by the undersigned. After due consideration of facts & circumstances

SANGAM ALMIRAH PRIVATE LIMITED,MUZAFFARPUR vs. NFAC, DELHI

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

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

80,091/- was held to be belonging to the proprietorship business but was debited in the account of the company and was disallowed. Penalty proceeding was also initiated and the order under section

MAHUA COOPERATIVE COLD STORAGE LTD, MAHUA,VAISHALI vs. ADIT,CPC, BENGALURU, BENGALURU

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

disallowing the interest payable to NCDC of Rs. 80,80,225 and 63,24,116 u/s 43B of the I.T. Act. 3) For that to decide that NCDC is a Public Financial Institution, the website of NCDC was analysed and on the basis of the activities listed, it has been presumed that it is a Public Financial Institution, whereas

SWARGIYA PROF NAWAL PD. SINGH S SANSTHAN,VAISHALI vs. CPC, BENGALURU

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.348/Pat/2025 Assessment Year: 2018-19 Swargiya Prof Nawal Pd. Singh S Sansthan…………………..………. …………………....Appellant 0 Sahi Colony, Hajipur, Vaishali, Bihar- 844101.. [Pan: Aagts5236E] Vs. Cpc, Bengaluru……..…....…..……………..………………….…..... Respondent Appearances By: Shri Rakesh Kumar, Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Is Directed By The Assessee Against The Order Dated 03.01.2025 Passed By The Cit, Appeal Addl/Jcit(A)-3, Chennai Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018–19. The Case Was Processed By The Cpc, Which Issued An Intimation Under Section 143(1) Of The Act, Disallowing The Assessee’S Claim Of Exemption Of ₹1,25,99,176, Being 80% Of The Total Expenditure Against Total Receipts Of ₹1,27,78,294. Consequently, The Total Income Was Determined At ₹₹1,27,78,294. I.T.A. No.348/Pat/2025 Swargiya Prof Nawal Pd. Singh S Sansthan 3. Aggrieved By The Above Intimation, The Assessee Preferred An Appeal Before The Cit(A). However, The Cit(A) Dismissed The Appeal Solely On The Ground That It Was Filed After A Delay Of 1,489 Days, Without Considering The Matter On Merits.

section 143(1) of the Act, disallowing the assessee’s claim of exemption of ₹1,25,99,176, being 80

DY COMMISSIONER OF INCOME TAX, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

Bench: Shri Rajpal Yadav & Dr. Manish Borad

80-IA has to be granted and the other agreements which are pure works contracts hit by the Explanation section 80IA(13), those work are not entitle for deduction under section 80IA of the Act. The profit from such contracts which involves development, operating, maintenance, financial involvement and defect correction and liability period is to be computed by Assessing Officer

DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

Bench: Shri Rajpal Yadav & Dr. Manish Borad

80-IA has to be granted and the other agreements which are pure works contracts hit by the Explanation section 80IA(13), those work are not entitle for deduction under section 80IA of the Act. The profit from such contracts which involves development, operating, maintenance, financial involvement and defect correction and liability period is to be computed by Assessing Officer

DY. COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1,PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

Bench: Shri Rajpal Yadav & Dr. Manish Borad

80-IA has to be granted and the other agreements which are pure works contracts hit by the Explanation section 80IA(13), those work are not entitle for deduction under section 80IA of the Act. The profit from such contracts which involves development, operating, maintenance, financial involvement and defect correction and liability period is to be computed by Assessing Officer

DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1, PATNA, PATNA vs. GANADHIPATI CONSTRUCTION PVT LTD, PATNA

In the result, all the appeals of the Revenue in ITA No

Bench: Shri Rajpal Yadav & Dr. Manish Borad

80-IA has to be granted and the other agreements which are pure works contracts hit by the Explanation section 80IA(13), those work are not entitle for deduction under section 80IA of the Act. The profit from such contracts which involves development, operating, maintenance, financial involvement and defect correction and liability period is to be computed by Assessing Officer

GYASUDDIN MOHAMMAD ANSARI,PURNIA vs. ITO, WARD- 3 (3), PURNEA

In the result, the appeal is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 80 E had been wrongly claimed. In fact, the assessee had sold a commercial is of land and furnish the working of capital loss of ₹ 240,000 and relied upon the decision of the Honourable Supreme Court in the case of gets a (India) Ltd vs CIT. The AO did not accept the contention of the assessee as according

RAKESH KUMAR,PATNA vs. DCIT, CIRCLE-4, PATNA

In the result, both the appeals of the assessee for AYs 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. Nos.85 & 86/Pat/2017 Assessment Years: 2012-13 & 2013-14

disallowing the claim of deduction u/ s BOIC of the act.” 5. Aggrieved, assessee is now in appeal before this Tribunal. 6. Ld. Counsel for the assessee submitted that the issue is no longer res integra that assembling of goods is also held to be a manufacturing activity because it gives rise to a new product with a new name

RAKESH KUMAR,PATNA vs. DCIT, CIRCLE-4, PATNA

In the result, both the appeals of the assessee for AYs 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. Nos.85 & 86/Pat/2017 Assessment Years: 2012-13 & 2013-14

disallowing the claim of deduction u/ s BOIC of the act.” 5. Aggrieved, assessee is now in appeal before this Tribunal. 6. Ld. Counsel for the assessee submitted that the issue is no longer res integra that assembling of goods is also held to be a manufacturing activity because it gives rise to a new product with a new name