PUSHPA KUMARI,PATNA vs. ITO, WARD-6(2), PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 7/Pat/2022 Assessment Year: 2015-2016 Pushpa Kumari,…………………..…...…………Appellant Rashtiriya Ganj, Station Road, Phulwari Sharif, Patna-801505, Bihar [Pan:Agmpk8844Q] -Vs.- Income Tax Officer,…..………………………...Respondent Ward-6(2), Patna Appearances By: Shri Prasoon Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 28, 2024 Date Of Pronouncing The Order: December 31, 2024 O R D E R

property possessed by the appellant. The assessee filed his return of income for the assessment year 2015-16, but not declared any capital gains in the financial year 2014-15 because the development work/process was not initiated by the developer. The assessee had not declared capital gains on such agreement as the builder had not acted upon as there

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

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 was a deemed transfer u/s 53A of the Transfer of Property

VIBHUTI BHUSHAN SINHA,DWARKA vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [PAN: DFSPS6397E] vs. ITO, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances by: Shri Sudipta Sannigrahi, CA, appeared on behalf of the appellant. Shri Sushil Kr. Mishra, JCIT-DR, appeared on behalf of the Respondent. Date of concluding the hearing : May 28, 2024 Date of pronouncing the order : August 12, 2024 आदेश / ORDER

SONAM RAJ,NEW DELHI vs. ITO, WARD-6(2), PATNA

In the result, both the appeals are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.02/Pat/2022 Assessment Years: 2015-16 Vibhuti Bhushan Sinha………………………….....…...……………....Appellant C-601, Shivam Apartment, Virmeshwar Nagar, Dwarka, Gujrat-361335. [Pan: Aigps7118D] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent I.T.A. No.03/Pat/2022 Assessment Years: 2016-17 Sonam Raj…………..………………………….....…...……………....Appellant W/O Shri Deepak Verma, 2Nd Floor, House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [Pan: Dfsps6397E] Vs. Ito, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca, Appeared On Behalf Of The Appellant. Shri Sushil Kr. Mishra, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 28, 2024 Date Of Pronouncing The Order : August 12, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By Two Different Assessees Against The Separate Orders Dated 30.04.2021 & 01.03.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To

House No.101, Pocket-52, Chittaranjan Park, New Delhi – 110019. [PAN: DFSPS6397E] vs. ITO, Ward-6(2), Patna…..….................................................…..…..... Respondent Appearances by: Shri Sudipta Sannigrahi, CA, appeared on behalf of the appellant. Shri Sushil Kr. Mishra, JCIT-DR, appeared on behalf of the Respondent. Date of concluding the hearing : May 28, 2024 Date of pronouncing the order : August 12, 2024 आदेश / ORDER

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

45,000/- only was deposited in savings Bank account 12. For that the provisions of section 69A do not apply in the appellant's case as she furnished her return on account of income from house property

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

house property’ and the assessee has also declared the agricultural income of Rs.39,45,200/- during the FY under consideration. As the assessee failed to establish the agriculture income as claimed by her in the return of income, therefore, it was concluded that the agricultural income shown by the assessee is nothing but unexplained money. The amount of Rs.39,45

DCIT, CENTRAL CIRCLE - 2(1), NAGPUR vs. KHARE AND TARKUNDE INFRASTRUCTURE PRIVATE LIMITED, NAGPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roydcit, Central Circle-2(1), Khare & Tarkunde Nagpur Vs Infrastructure Pvt. Ltd., 235, Shivaji Complex, Dharmpeth, Nagpur Pan : Aaack 7184 N Department Assessee Assessee By : Shri Sachin V. Luthra, Ca Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 21.04.2026 O R D E R

property in the form of TDRs at a consideration significantly lower than the stamp duty value/market value. Therefore, the difference was rightly brought to tax to prevent undervaluation of transactions. The Ld. DR contended that TDRs are intrinsically linked to land and building and hence fall within the scope of “land or building or both” as envisaged under section 43CA

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 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, 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

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

KAMLESH KUMAR,PATNA vs. ITO WARD- 6 (4), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraι.Τ.Α. No.: 147/Pat/2025

Property Act, 1882, thus the capital Gain as assumed, ascertained and computed/calculated hypothetically by the Ld. A.O. only on the basis of so called development agreement and possibility of fulfilment of terms and conditions thereof has caused miscarriage of justice which cannot be sustainable under the provisions of law. And, in support of the above facts

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

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

Housing of Hon’ble Karnataka High Court. He also relied upon the judgment of the Hon’ble Kerala High Court in the case of E.N. Gopakumar –vs.- CIT reported in 390 ITR 131. 6. Ld. Counsel for the assessee while impugned the order of the ld. CIT(Appeals) on this fold submitted that the assessee is not disputing about

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.

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

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

45 to 249 09 Reply of assessee- ANN-5 250 to 256 10 Reply of Notice u/s 142(1)- ANN-6 257 11 Reply of notice u/s 142(1)- ANN-7 258 to 284 12 Reply of notice u/s 142(1) -ANN-8 285 to 319 13 Reply of assessee-ANN-9 321 to 351 14 Order sheet details

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

45 to 249 09 Reply of assessee- ANN-5 250 to 256 10 Reply of Notice u/s 142(1)- ANN-6 257 11 Reply of notice u/s 142(1)- ANN-7 258 to 284 12 Reply of notice u/s 142(1) -ANN-8 285 to 319 13 Reply of assessee-ANN-9 321 to 351 14 Order sheet details

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

45 to 249 09 Reply of assessee- ANN-5 250 to 256 10 Reply of Notice u/s 142(1)- ANN-6 257 11 Reply of notice u/s 142(1)- ANN-7 258 to 284 12 Reply of notice u/s 142(1) -ANN-8 285 to 319 13 Reply of assessee-ANN-9 321 to 351 14 Order sheet details

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

45 to 249 09 Reply of assessee- ANN-5 250 to 256 10 Reply of Notice u/s 142(1)- ANN-6 257 11 Reply of notice u/s 142(1)- ANN-7 258 to 284 12 Reply of notice u/s 142(1) -ANN-8 285 to 319 13 Reply of assessee-ANN-9 321 to 351 14 Order sheet details