ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S AL-KARIM EDUCATIONAL TRUST, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

House No. B-76, Khesara No. 635/245, Village Jasola, New Delhi-110025 construction is in progress but name of the owner of the property could not be ascertained from local enquiry. • Shri Pratap Singh, Rajesh Kr. And Ranveer Kr. Singh (all sons of Moolchand Chauhan) could not be traced on the address as furnished by the assessee. • Shri

ACIT CENTRAL CIRCLE-2, PATNA vs. AHMAD ASHFAQUE KARIM, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

House No. B-76, Khesara No. 635/245, Village Jasola, New Delhi-110025 construction is in progress but name of the owner of the property could not be ascertained from local enquiry. • Shri Pratap Singh, Rajesh Kr. And Ranveer Kr. Singh (all sons of Moolchand Chauhan) could not be traced on the address as furnished by the assessee. • Shri

ACIT, CENTRAL CIRCLE-2, PATNA vs. NUZHAT NASREEN, L/H AHMAD ASHFAQUEKARIM OF NUZHAT NASREEN, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

House No. B-76, Khesara No. 635/245, Village Jasola, New Delhi-110025 construction is in progress but name of the owner of the property could not be ascertained from local enquiry. • Shri Pratap Singh, Rajesh Kr. And Ranveer Kr. Singh (all sons of Moolchand Chauhan) could not be traced on the address as furnished by the assessee. • Shri

ACIT, CENTRAL CIRCLE-2, PATNA vs. M/S AL-KARIM EDUCATIONAL TRUST, PATNA

In the result, all the appeals of the revenue i

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. Nos. 67 & 68/Pat/2021 Assessment Years: 2013-14 & 2014-15 Acit, Central Circle-2, Patna Vs. M/S. A1-Karim Educational Trust Katihar Lane, Bailey Road, Khajpura Patna-800014 (Pan: Aaatm6309G) (Appellant) (Respondent) &

House No. B-76, Khesara No. 635/245, Village Jasola, New Delhi-110025 construction is in progress but name of the owner of the property could not be ascertained from local enquiry. • Shri Pratap Singh, Rajesh Kr. And Ranveer Kr. Singh (all sons of Moolchand Chauhan) could not be traced on the address as furnished by the assessee. • Shri

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT (CENTRAL), PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

HARI NARAYAN GUPTA (HUF),PATNA vs. ITO, WARD- 6 (5), PATNA

In the result, the appeal of the assessee is allowed

13-02-2003], however,\nthe facts are distinguishable as in that case the substantial payments\nwere made at the time of execution of joint development agreement.\nAfter hearing the rival contentions and perusing the materials\navailable on record, we find that the assessee has entered into a\nLand Development Agreement with the builder as stated hereinabove\nand builder has been

SHARDINDU PRASAD SINGH,PATNA vs. ITO, WARD-6(4), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

8. Ld. AO has erred in invoking section 2(47)(v), 45 and 48 of the I.T. Act, 1961 and section 53A of The Transfer of Property Act, 1882. On the facts and in the circumstances of the case, the learned Assessing Officer has erred in holding that the transfer of 55% of the Land in favour of the Developer

PRABHAT KUMAR,PATNA vs. ACIT, CIRCLE-4, PATNA

Appeal is allowed\nfor statistical purposes

8,85,666/- added on account of difference in income shown in\nreturn with that available in Form 26AS.\n2.2 Aggrieved with this action, the assessee approached the Ld. CIT(A)\nwhere also he could not succeed mainly for the reason that he did not\nattend to any of the 5 notices sent to him for presenting his submissions\netc

USHASHREE DEVI,BHAGALPUR vs. PR.CIT-1, PATNA

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

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No. 42/Pat/2021 Assessment Year: 2017-18 Ushashree Devi, Sabjee Chowk, Barari, Bhagalpur - 812003 [Pan: Aeppd6663K] ……….......................…...……………....Appellant Vs. Principal Commissioner Of Income Tax, Patna – 1, Central Revenue Building, Birchand Patel Marg, Patna - 800001 ............…..........................…..…..... Respondent

8. For that the CIT (A) erred in confirming the addition amounting to Rs 15,45,000/- made by the AO on account of assumed deposits in bank under section 69A, on wrong facts of the case, as she is deriving income from various sources of income as accepted by AO and has sufficient assets since 2008 to justify

AJAY KUMAR,PATNA vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is allowed

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

house property and income from other source, namely interest etc. As observed above, the ld. Assessing Officer has examined all these details and thereafter finalized the assessment. 4. The ld. Pr. Commissioner on perusal of the assessment record formed an opinion that assessment order is suffering from an apparent error and, therefore, it has caused a prejudice to the interest

GRAM NIRMAN MANDAL,NAWADA vs. DC/AC EXEMPTION, CIR, PATNA, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

8) For that, delay of filling of 10B, was caused due to the negligence of the of the chartered Accountant, assessee should not be punished for mistake. 9) For that, Allahabad High Court held in the case of C.I.T vs Kesar Enterprises Ltd(2010) 325 ITR 713 (ALL) that Delay was caused due to the negligence of the chartered Accountant

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

Bench: Shri Sonjoy Sarma, Hon’Blei.T.A. No. 175 To 178/Pat/2023 Assessment Year: 2015-16 To 2018-19 Gyan Infrabuild Private Limited Principal Commissioner Of Awlespur, Kandwa Vs Income-Tax (Central), Patna Varanasi - 221006 [Pan: Aaecg0509Mc] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, Adv. Revenue By : Md. A.H. Chowdhary, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 05/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 13/05/2024 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate & Identical Orders Of The Learned Principal Commissioner Of Income Tax (Central), Patna (Hereinafter The “Ld. Pr. Cit”) Even Dt. 26/03/2022, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2015-16 To 2018-19. 2. The Registry Has Pointed Out That There Is A Delay Of 14 Days In Filing Of These Appeals. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. Relevant Content Of The Petition Dt. 08/06/2023 Is Extracted For Ready Reference:- “…….. 1. That We Had Received An Order U/S 263 Passed By Id Principal Commissioner Of Income-Tax, Central Circle, Patna On 26.03.2022. 2

13-02- 2015 following the decision of the Lucknow Bench of the Tribunal in the case of MehtabAlam (Supra) held that CIT is not justified in assuming jurisdiction u/s.263 when the order has been passed in terms of section 153D of the Act. 14.2 We find the Hyderabad Bench of the Tribunal in the case of M/s. Trinity Infra Ventures