ACIT, 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]

section 54F & 54EC of the Act is hereby deleted. As regards the addition on account of disallowance of claim of loan liability to the tune of Rs. 34,00,000/- On perusal of assessment order, it is observed that after availing several opportunities the appellant has not provided the reason why the name of M/s Rohit ITA Nos. 96 & 98/PAT/2021

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]

section 54F & 54EC of the Act is hereby deleted. As regards the addition on account of disallowance of claim of loan liability to the tune of Rs. 34,00,000/- On perusal of assessment order, it is observed that after availing several opportunities the appellant has not provided the reason why the name of M/s Rohit ITA Nos. 96 & 98/PAT/2021

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]

section 54F & 54EC of the Act is hereby deleted. As regards the addition on account of disallowance of claim of loan liability to the tune of Rs. 34,00,000/- On perusal of assessment order, it is observed that after availing several opportunities the appellant has not provided the reason why the name of M/s Rohit ITA Nos. 96 & 98/PAT/2021

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]

section 54F & 54EC of the Act is hereby deleted. As regards the addition on account of disallowance of claim of loan liability to the tune of Rs. 34,00,000/- On perusal of assessment order, it is observed that after availing several opportunities the appellant has not provided the reason why the name of M/s Rohit ITA Nos. 96 & 98/PAT/2021

ACIT, CENTRAL CIRCLE-1, PATNA vs. SONAMOTI AGROTECH PVT LTD, PATNA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

87,00,000/- made by the ld. Assessing Officer with the aid of section 68 of the Income Tax Act. It is pertinent to note that the ld. 1st Appellate Authority has decided the appeals for A.Ys. 2011-12 to 2013-14 by the common impugned order. 2 Assessment Year: 2012-2013 & C.O. No. 04/PAT/2022 (in ITA No. 110/PAT/2019) Assessment

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1, PATNA., FOURTH FLOOR, DAKBUNGLOW CHAURAHA, PATNA vs. BIHAR RAJYA PUL NIRAMAN NIGAM LIMITED, SARDAR PATEL MARG, PATNA

Appeal of the Revenue is dismissed and CO filed by the assessee is allowed

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

disallowance of Rs. 2,87,93,267/- booked as an expense under the head “Corporate Social Responsibility” (CSR) at the level of Ld. AO it appears that the impugned amount has been added due to the assessee not being able to present a satisfactory reply to justify the said expense with respect to a business purpose. 2.1 Aggrieved with this

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.

disallowed the said amount on the ground that mere establishing the identity of the creditor or the transaction have been routed through banking channel is not enough to prove the creditworthiness and genuineness of the transaction. On appeal, the CIT(A) called for remand report from the Assessing officer and after considering the same confirmed the addition. However, the Tribunal

SANOJ KUMAR SINGH ,HAJIPUR vs. ITO, WARD-1(3) , VAISHALI

The appeal of the revenue stands dismissed

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI RAJESH KUMAR (Accountant Member)

Section 68 of the Act as unexplained cash credit u/s 68 of the Act. The Assessing Officer computed the disallowance merely on an estimation basis, the As- sessing Officer noted that total turnover/sales of the assessee during the year were Rs. 5,07,59,673/- out of which the assessee has deposited cash to the tune of Rs. 1,87

PIYUSH & ASSOCIATES PRIVATE LIMITED,PATNA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

ACIT, CENTRAL CIRCLE-1, PATNA vs. PIYUSH & ASSOCIATES PRIVATE LIMITED, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

ACIT, CENTRAL CIRCLE-1, PATNA vs. PROMINENT FINANCIAL ADVISORY PVT LTD, KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

ACIT, CENTRAL CIRCLE-1, PATNA vs. PROMINENT FINANCIAL ADVISORY PVT LTD, KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

PROMINENT FINANCIAL ADVISORY PVT LTD,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, PATNA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.99/Pat/2021 Assessment Year: 2013-14 Acit, Central Circle -1 Piyush & Associates Private Ltd. Patna, 6Th Floor, C.R. (Annexee) Vs Pirmohani, Kadamkuan, Patna, Building, Bir Chand Patel Path, Bihar-800003 Patna-800001 [Pan : Aadcp3041N] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

section. This group was subjected to search and seizure action u/s 132 of the Act ITA Nos.78,79,80,99,102,103/Pat/2021 conducted on 15th March, 2018. On account of search, assessment proceeding for preceding six assessment years were initiated by way of issuing valid notice u/s 143(2) and 142(1) of the Act after the assessee had furnished

RAINBOW ESTATES P LTD,BANDAR BACHICHA vs. CPC, BANGLORE

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

87,161/- thereby creating demand of Rs. 99,570/-. The assessee filed rectification application u/s 154 of the Act on 16.12.2022 but the same was rejected by CPC on the same date. The assessee filed the appeal against the processing of the return before the Ld. CIT(A) but vide order dated 23.06.2023, the appeal of the assessee was dismissed

SANJAY YADAV,JAHANABAD vs. NFAC, DELHI, DELHI

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Rakesh Mishra

section 142(1) of the Income- tax Act which is wrong, illegal and unjustified on the facts of the case. 4. For that the Ld. CIT (A) NFAC has failed to appreciate that no penalty is livable sustainable u/s 271(1)(b) in view of order of the Jurisdictional Tribunal directly on the issue which has been followed in umpteen

SANJAY YADAV,JAHANABAD vs. NFAC, DELHI, DELHI

In the result, all the three appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Rakesh Mishra

section 142(1) of the Income- tax Act which is wrong, illegal and unjustified on the facts of the case. 4. For that the Ld. CIT (A) NFAC has failed to appreciate that no penalty is livable sustainable u/s 271(1)(b) in view of order of the Jurisdictional Tribunal directly on the issue which has been followed in umpteen