GANESH RAM DOKANIA,BANKA vs. ACIT, CIR-2, PATNA, PATNA
In the result, the appeal of the assessee is allowed
ITA 238/PAT/2025[2014-15]Status: DisposedITAT Patna08 Jan 2026AY 2014-15
Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Years: 2014-15 Ganesh Ram Dokania………..……..………………….……….……….……Appellant Dokania Market, Aliganj, Bihar-813102.. [Pan: Aadfg1795P] Vs. Acit, Circle-2, Patna…….………...…………………….....……...…..…..Respondent Appearances By: Shri Manish Rastogi, Adv., Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2025 Date Of Pronouncing The Order : January 08, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Of The Cit(A)-3, Patna (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2014–15. 2. Facts In Brief Are That The Assessee Is Engaged In Real Estate Business & The Assessee Filed Return Of Income On 15.11.2016 In Response To Notice U/S 153A Of The Act By Declaring Total Income Of Rs.31,56,350/-. Notice U/S. 143(2) Of The Act Was Issued & Subsequently, Assessment U/S. 153A/144 Was Completed At A Total Income Of Rs.25,67,79,232/- Wherein The Assessing Officer Imposed Penalty U/S. 271Aab Of The Act At Rs. 1,60,00,000/- On Undisclosed Income.
Section 143(2)Section 153ASection 250Section 271(1)(c)Section 271ASection 274
73 taxmann.com 248/242 Taxman 180 (SC). On the same lines it is the decision of this court in Pr. CIT v. Brijendra Kumar
Poddar in [ITAT No. 215 of 2018, dated 23-11-2021]. As pointed out earlier, the show cause notice issued under Section 274 read with Section 271 of the Act did not furnish any particulars