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.

undisclosed income of t, assessee company Repelling such contention. the Hon'ble High Court of Kolke observed that "The judgment in Commissioner of Income Tax vs. Lovely Exports F Ltd was rendered in the particular facts and circumstances of that case. The judgment may not lay down any proposition of law that operates as a binding precedent on ti Court

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

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

undisclosed income. Thus, while in view of the mandate of sub-section (1) of section 153A of the Act, in every case where there is a search or requisition, the Assessing Officer is obliged to issue notice to such person to furnish returns of income for the six years preceding the assessment year relevant to the previous year in which

KUMAR SUMAN SINGH,PATNA vs. DCIT, CENTRAL CIRCLE-2, PATNA

In the result, I.T.A. Nos

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.212 To 216/Pat/2023 Assessment Years: 1998-99 & 2001-02 To 2004-05 Kumar Suman Singh………………………..……………………………...……Appellant F-62, P.C. Colony, Kankarbagh, Patna, Bihar – 800020. [Pan: Aihps1976L] Vs. Acit, Central Circle-2, Patna…………....….…......……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit – Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : January 09, 2025 Order Per Bench: These Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 1998-99 & 2001-02 To 2004-05 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Mostly Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That There Is A Delay Of 132 Days In Filing The Instant Appeals. The Assessee Has Submitted Applications For Condonation Of Delay Citing Reasonable Grounds. After Considering The Averments Made In The Applications, We Condone The Delay.

undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by the Assessing Officer as there was no separate

KUMAR SUMAN SINGH,PATNA vs. ACIT CENTRAL CIRCLE-2, PATNA

In the result, I.T.A. Nos

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.212 To 216/Pat/2023 Assessment Years: 1998-99 & 2001-02 To 2004-05 Kumar Suman Singh………………………..……………………………...……Appellant F-62, P.C. Colony, Kankarbagh, Patna, Bihar – 800020. [Pan: Aihps1976L] Vs. Acit, Central Circle-2, Patna…………....….…......……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit – Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : January 09, 2025 Order Per Bench: These Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 1998-99 & 2001-02 To 2004-05 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Mostly Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That There Is A Delay Of 132 Days In Filing The Instant Appeals. The Assessee Has Submitted Applications For Condonation Of Delay Citing Reasonable Grounds. After Considering The Averments Made In The Applications, We Condone The Delay.

undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by the Assessing Officer as there was no separate

KUMAR SUMAN SINGH,PATNA vs. ACIT, CENTRAL CIRCLE-2, PATNA

In the result, I.T.A. Nos

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.212 To 216/Pat/2023 Assessment Years: 1998-99 & 2001-02 To 2004-05 Kumar Suman Singh………………………..……………………………...……Appellant F-62, P.C. Colony, Kankarbagh, Patna, Bihar – 800020. [Pan: Aihps1976L] Vs. Acit, Central Circle-2, Patna…………....….…......……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit – Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : January 09, 2025 Order Per Bench: These Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 1998-99 & 2001-02 To 2004-05 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Mostly Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That There Is A Delay Of 132 Days In Filing The Instant Appeals. The Assessee Has Submitted Applications For Condonation Of Delay Citing Reasonable Grounds. After Considering The Averments Made In The Applications, We Condone The Delay.

undisclosed income. Subsequent to the assessment, it was found that the assessee had used multiple alias names such as Indrajeet Kumar (Singh) and Ranjit Singh. Later on, income was assessed in the name of Indrajeet Kumar and merged with the assessed income of the assessee which was ultimately brought to tax by the Assessing Officer as there was no separate

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. AJIT KUMAR, BETTIAH

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

disallowance as the said would amount to double addition. 8. We have considered the submissions made and have also gone through the order of the Ld. CIT(A) who had called for the remand report, analysed the impounded documents and thereafter recalculated the undisclosed sales on which gross profit rate has been applied and additional income

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

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)

Income tax department. Acknowledgment of same is also enclosed with this submission. In the light of above facts and self-admission of id AO raising doubt on the figures of the pen drive, the impugned addition is not sustainable and may kindly be deleted.” 8. Considering the contentions of the assessee as well as the settled judicial precedents

VIJAYA SINGH,PATNA vs. INCOME TAX OFFICER, WARD - 6(1), PATNA, PATNA, BIHAR

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 519/Pat/2024 Assessment Year: 2018-2019 Vijaya Singh,…………………………...….………Appellant M-55/22A, S.K. Nagar, Patna-800001, Bihar [Pan:Asups6086N] -Vs.- Income Tax Officer,………………………......Respondent Ward-6(1), Patna, Lok Nayak Jay Prakash Bhawan, Dak Bunglow Road, Patna-800001, Bihar

undisclosed income under section 68 of the Income Tax Act and also taxed as per section 115BBE. Ld. Counsel further submitted that the interest also arbitrarily charged under section 234B for an amount of Rs.11,49,462/-, therefore, he pleaded to set aside the orders passed by the lower authorities. 6. On the other hand, it was the submission

ANUP KUMAR HUF,PATNA vs. ACIT, CENT. CIR-1, PATNA, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 192/Pat/2025 Assessment Year: 2014-2015 Anup Kumar Huf,…………………...….………Appellant 4A, Narayan Nilayam Apartment, Road No. 6 Rajendra Nagar, Patna-800016 Bihar [Pan:Aahha5422R] -Vs.- Assistant Commissioner Of Income Tax....Respondent Central Circle-1, Patna

disallowed Rs.15,11,000/- and added back to the total income of the assessee as undisclosed income from other sources

ITO, WARD-2(1), BEGUSARAI, BEGUSARAI vs. MANISH KUMAR MOTANI, KHAGARIA, BIHAR

In the result, the appeal of the Revenue and CO of the Assessee are dismissed

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Appellant) (Respondent) Pan No. Ajjpm4263D Co No. 02/Pat/2025 (Arising In Ita No. 442/Pat/2024 For A.Y. 2017-18) Ito, Ward 2(1), Begusarai Manish Kumar Motani, 3Rd Floor, G.S. Motors Building, Manish Kumar Motani, Hanuman Har Har Mahadev Chauk, Traders, Mill Road, Khagaria, Vs. Begusarai-851101, Begusarai, Khagaria, Bihari-851204 Bihar-851101 (Applicant) (Respondent) Assessee By : S/Shri A.K. Rastogi, S.K. Duta, Ars Revenue By : Shri A.H. Chowdhary, Dr Date Of Hearing: 24.11.2025 Date Of Pronouncement: 26.02.2026

income of ₹34,62,020/- by making the two additions (i) ₹8,02,45,293/ - in respect of undisclosed sales and (ii) 16,88,598/-, in respect of disallowance

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

undisclosed income on unrecorded purchases. Both the authorities have made analysis of the 10 Assessment Year: 2010-2011 Ashok Kumar material found during the course of survey. The assessee failed to submit any material to rebut the conclusions of facts arrived at by the revenue authorities below. Therefore, we do not find any merit in this ground of appeal

ITO, WARD-2(1), BEGUSARAI vs. SMT. SATAYABATI DEVI, KHAGARIA

In the result, the appeal of the Revenue as well as the Cross Objection by the assessee both are dismissed

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

disallowed as such but has added the mount because of having been paid towards this expense out of undisclosed sources of income

KUMAR ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], 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]

undisclosed income also, provision of section 142,143(2) and 143(3) of the Act are applicable and no assessment can be madewithout issuing notice under section 143(2) of the Act. 5. In the case of Sanjeev Aggarwal Vs. DCIT [2016] 70 taxmann.com 265(Chandigarh-Trib.) the Hon'ble Chandigarh Tribunal has held that where theAssessing Officer passed