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) &

34 Officer shall not be required to issue notice for assessing or reassessing the total income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made 2 [and for the relevant assessment year or years as referred to in sub-section (1) of section 153A] except

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) &

34 Officer shall not be required to issue notice for assessing or reassessing the total income for six assessment years immediately preceding the assessment year relevant to the previous year in which search is conducted or requisition is made 2 [and for the relevant assessment year or years as referred to in sub-section (1) of section 153A] except

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

In the result, the appeal is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

34,383/- on account of purchase of residential house property at Delhi out of sale proceeds of land at Patna. 5. For that the Ld. CIT(A), NFAC has erred in holding that the assessee has not furnished the requisite details regarding claim of deduction u/s 54F either before the A.O. or during the appellate proceeding whereas the fact remains

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

Appeal is allowed\nfor statistical purposes

34,608 (Actual cost of improvement Rs.12,01,200 X 264/184)\nclaimed by the appellant in its return of income for the purpose of long term capital\ngain and taxing the same as capital gain, notwithstanding the fact that the\nappellant has given sufficient documentary evidences before the Id assessing\nofficer to substantiate the claim of cost of improvement

VIDYA SAGAR SINGH HUF THROUGH KARTA SANTOSH KUMAR SINGH,PATNA vs. ITO, WARD- 6 (4), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

34,000/- made u/s 69A of the Income Tax Act. 6. For that the whole order is bad in fact and law of the case and is fit to be restored back to the file of CIT(A) and/or the Assessing Officer particularly in view of insertion of proviso below clause (a) of section 1 of section 251 by Finance

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]

housing loan of Rs. 1,97,16,393/- on 22.03.2016 which is presumably related to any other property as the cost of properly acquired from M/s Bestech (erroneously referred to as Ms Unitech in the show cause notice) itself is merely Rs. 1,11,53, 500/- e. Notwithstanding above, the assessee has claimed total exemption u/s 54F for an amount

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]

housing loan of Rs. 1,97,16,393/- on 22.03.2016 which is presumably related to any other property as the cost of properly acquired from M/s Bestech (erroneously referred to as Ms Unitech in the show cause notice) itself is merely Rs. 1,11,53, 500/- e. Notwithstanding above, the assessee has claimed total exemption u/s 54F for an amount

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]

housing loan of Rs. 1,97,16,393/- on 22.03.2016 which is presumably related to any other property as the cost of properly acquired from M/s Bestech (erroneously referred to as Ms Unitech in the show cause notice) itself is merely Rs. 1,11,53, 500/- e. Notwithstanding above, the assessee has claimed total exemption u/s 54F for an amount

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]

housing loan of Rs. 1,97,16,393/- on 22.03.2016 which is presumably related to any other property as the cost of properly acquired from M/s Bestech (erroneously referred to as Ms Unitech in the show cause notice) itself is merely Rs. 1,11,53, 500/- e. Notwithstanding above, the assessee has claimed total exemption u/s 54F for an amount

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]

housing loan of Rs. 1,97,16,393/- on 22.03.2016 which is presumably related to any other property as the cost of properly acquired from M/s Bestech (erroneously referred to as Ms Unitech in the show cause notice) itself is merely Rs. 1,11,53, 500/- e. Notwithstanding above, the assessee has claimed total exemption u/s 54F for an amount

RAVI LOCHAN SINGH,PATNA vs. ACIT, CIRCLE-5, PATNA

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

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

housing loan for flat no. 5D, Malayalay. Hence this addition of the AO is confirmed, and the appeal of the assessee is dismissed on this ground. Ground No- 6 regarding disallowance of Rs. 2,98,145/- on account of 50% of interest on loan taken for purchases of property 2W, The Millennium Building. This ground is same nature as ground

GANADHIPATI CONSTRUCTION PRIVATE LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

34. We also notice that in the recent decision of this tribunal in the case of Gyan Infrabuild (P) Ltd.(supra) the facts are almost identical because in the case of Gyan Infrabuild (P) Ltd.(supra) also search was carried out and Ld. AO completed the assessment proceeding after making detailed enquiry and also got the approval u/s. 153D

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

34. We also notice that in the recent decision of this tribunal in the case of Gyan Infrabuild (P) Ltd.(supra) the facts are almost identical because in the case of Gyan Infrabuild (P) Ltd.(supra) also search was carried out and Ld. AO completed the assessment proceeding after making detailed enquiry and also got the approval u/s. 153D

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

34. We also notice that in the recent decision of this tribunal in the case of Gyan Infrabuild (P) Ltd.(supra) the facts are almost identical because in the case of Gyan Infrabuild (P) Ltd.(supra) also search was carried out and Ld. AO completed the assessment proceeding after making detailed enquiry and also got the approval u/s. 153D

GANADHIPATI CONSTRUCTION PVT LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

34. We also notice that in the recent decision of this tribunal in the case of Gyan Infrabuild (P) Ltd.(supra) the facts are almost identical because in the case of Gyan Infrabuild (P) Ltd.(supra) also search was carried out and Ld. AO completed the assessment proceeding after making detailed enquiry and also got the approval u/s. 153D

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL , PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

34. We also notice that in the recent decision of this tribunal in the case of Gyan Infrabuild (P) Ltd.(supra) the facts are almost identical because in the case of Gyan Infrabuild (P) Ltd.(supra) also search was carried out and Ld. AO completed the assessment proceeding after making detailed enquiry and also got the approval u/s. 153D

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

Housing Projects Ltd. (supra), find that the ld. Pr. CIT has merely referred to the seized material but has not made any further enquiry about the correctness of such documents, as to whether they belong to the assessee, or pertain to the year under consideration. 28. We find that the learned PCIT in his show cause notice has referred

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

Housing Projects Ltd. (supra), find that the ld. Pr. CIT has merely referred to the seized material but has not made any further enquiry about the correctness of such documents, as to whether they belong to the assessee, or pertain to the year under consideration. 28. We find that the learned PCIT in his show cause notice has referred