ALKEM LABORATORIES LTD,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

deduction under section 35(2AB) amounting to Rs.71.43 crores and not in respect of the commission payments. The reassessment proceeding

ANIL KUMAR,NALANDA vs. ITO, WARD- 2 (3), BIHARSHARIF

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Dr. Manish Boradi.T.A. No. 361/Pat/2023 Assessment Year: 2014-15 Anil Kumar National Faceless Assessment Centre M/S Raj Trading Company, Nfac, Delhi Harnaut, Nalanda, Patna-803110 Vs Bihar [Pan : Azopc268H] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

reassessment proceedings making disallowance u/s 40(a)(ia) of the Act at ₹1,44,000/- for non-deduction of tax at source

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.

deduction, allowance or relief in the return;] (d) Where a person is found to have any asset (including financial interest in any entity) located outside India.] ^[Explanation 3.—For the purpose of assessment or reassessment

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment proceedings, the Ld. AO disallowed the sums of ₹55,19,700/- (being the sums of ₹54,59,700/- out of freight charges plus ₹60,000/- on account of accounting charges) for non-deduction

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

BIHAR STATE ROAD DEVELOPMENT CORPN.LTD.,PATNA vs. CIT (APPEAL), DELHI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ITO WARD 2(1) PATNA, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction

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

reassessment proceedings, the AO analyzed the impounded materials. Books of accounts produced by the assessee, were also examined. Thereafter an order u/s 143(3) was passed on 30.12.2019. Following additions were made to the declared income of the assessee of Rs 11,85,340/- in return filed in compliance to u/s 148 of as below: (a) On the basis

MOHAMMAD TANWEER ALI IMAM,PATNA vs. ITO, WARD- 5(1), PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Mohammad Tanweer Ali Imam, Income Tax Officer, Darul Aman Po Bv College, Ward 5(1), Patna Samanpura, Rajabazar, Vs. Patna-800014 (Appellant) (Respondent) Pan No. Aanpi1722J Assessee By : Shri Manish Rastogi, Ar Revenue By : Shri Ashwani Kr. Singal, Dr Date Of Hearing: 08.07.2025 Date Of Pronouncement: 22.07.2025

deduction of tax on transfer of Rs 1,10,00,000/- from NRO to NRE bank account, which was received from maturity of fixed deposit out of his taxable income for FY 2015-16 relevant to AY 2016-17. Thus it is believed that this amount has escaped assessment and chargeable to tax.” 08. We note that amount transferred from

SANJAY KUMAR ,PATNA vs. ITO WARD-4(5) PATNA , PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

deduction of tax. Therefore, the Bench was of the view that in the interest of justice and since the assessee was not properly represented before both the Ld. AO as well as the Ld. CIT(A), the order of the Ld. CIT(A) ought to be set aside for granting another opportunity to the assessee of being heard. Hence, after

PUNRASAR JUTE PARK LIMITED,PURNEA vs. CIT, PURNEA

In the result, the appeal of the assessee is allowed

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

reassessment the Assessing Officer has to mention what was the tangible material to come to the conclusion that there is an escapement of income from assessment and that there has been a failure to fully and truly disclose material fact. After a period of four years even if the Assessing Officer has some tangible material to come to the conclusion

ALKEM LABORATORIES LIMITED,PATNA vs. ACIT, CIRCLE-1, PATNA

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

deduction u/s 80HHC of the Act. In the result, Ground Nos. 1 & 2 of the assessee are allowed. 9. Now we take up Ground Nos. 3 to 7 which relates to the correctness of interest charged u/s 234B of the Act. The ld. Counsel for the assessee has contended that the regular assessment

ARCHANA,PATNA vs. ITO, WARD- 4 (1), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment proceeding has been initiated for making roving and fishing enquiry. The order of assessment as sustained u/s 147 rws 144 rws 144B is arbitrary, unjustified, without jurisdiction, void ab-initio, bad in law, vitiated in law and invalid. The order as passed u/s 147 is fit to be quashed / cancel / annulled. 1.2 For that the order of the assessment

ACIT vs. INTERNATIONAL SCHOOL OF SOCIAL WELFARE HUMAN RESOURCES,

In the result, the appeal filed by the Revenue is allowed while the Cross Objection filed by the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

reassess such income, other than the income involving matters which are the subject-matter of any appeal, reference or revision, which is chargeable to tax and has escaped assessment.] Explanation 1.—Production before the Assessing Officer of account books or other ev- idence from which material evidence could with due diligence have been discovered by the Assessing Officer will

THE MUZAFFARPUR CENTRAL CO-OPERATIVE BANK LTD,MUZAFFARPUR vs. ACIT, CIRCLE-2, MUZAFFARPUR

In the result, the appeal of the assessee stands dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.224/Pat/2019 Assessment Year: 2009-10 The Muzaffarpur Central Co-Operative Bank Ltd....…...……………....Appellant Sadar Hospital Road, Muzaffarpur, Bihar – 842001. [Pan: Aabat7831Q] Vs. Acit, Circle-2, Muzaffarpur….................................................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, 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 : July 11, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.07.2019 Of The Commissioner Of Income (Appeal), Muzzafarpur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Though The Assessee In This Appeal Has Taken As Many As Six Grounds Of Appeal, However, The Sole Issue Raised By The Assessee In This Appeal Is Relating To The Validity Of The Reopening Of The Assessment. 3. The Brief Facts Of The Case Are That The Assessee Is A Cooperative Bank & Derives Income From Banking Business. The Assessing Officer Noted That The Assessee Had Not Filed Its Return Of Income For The Assessment Year 2009-10 Despite Having Taxable Income. He, Therefore

reassessment proceedings u/s 147 of the Act for assessment years 2009-10 and 2010-11. However, the assessee informed vide letter dated 11.10.2011 that it has already filed return of income for the year under consideration on 09.08.2010. The ACIT noted that the assessee was supposed to file the return of income with his circle, however, he had filed