G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

reassessment order by issuance of a notice under section 148(a) of the Income Tax Act. At first instance, the assessee thought that there was no need to file the appeal, but later on when it consulted with ld. Sr. Counsel, it was advised to file an appeal. In that process, the delay of 14 days had occurred. The assessee

G D MOTHER EDUCATIONAL SOCIETY,MUZAFFARPUR vs. ACIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 307, 308 & 309/Pat/2024 Assessment Years: 2018-19, 2019-20 & 2020-21 G D Mother Educational Society,…..…….……Appellant Akharaghat Road, Muzzaffarpur-842001, Bihar [Pan:Aaaag3023A] -Vs.- Assistant Commissioner Of Income Tax,..…Respondent Central Circle, Muzaffarpur, Aayakar Bhawan, Near Nehru Stadium, Sikandarpur, Muzzaffarpur-842001, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate & Puja Somani, Ca, Appeared On Behalf Of The Assessee Smt. Rinku Singh, Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 04, 2024 Date Of Pronouncing The Order: September 25, 2024 O R D E R

reassessment order by issuance of a notice under section 148(a) of the Income Tax Act. At first instance, the assessee thought that there was no need to file the appeal, but later on when it consulted with ld. Sr. Counsel, it was advised to file an appeal. In that process, the delay of 14 days had occurred. The assessee

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

reassessment order was cancelled. Subsequently, the Ld. AO reopened the assessment by recording reasons on16.04.2009 i.e. after the Ld. CIT(A) had cancelled the assessment made on 19.12.2007 on account of non-service of the notice u/s 143(2) the Act. The reasons recorded on 18.01.2007 for the 1st reopening and those recorded on 16.04.2009 for the 2 nd reopening

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

NAND KUMAR PRASAD SAH,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR

In the result, all the appeals of the assessee (s) in ITA Nos

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

reassessment, referred to in clause (a) of sub- section (1), in a case where an order under sub-section (4) has been made accepting the application.”. ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 011. Now, from perusal of the above Section, we note that so far as the conditions mentioned

SANGAM ALMIRAH PRIVATE LIMITED,MUZAFFARPUR vs. NFAC, DELHI

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

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

23,314/- towards Provident Fund, EPS and ESI. The expenditure debited was for the period 01.04.2017 to 31.03.2018. As the assessee-company had started its business from 01.07.2017 the expenditure debited for the period 01.04.2017 to 30.06.2017 amounting to Rs.3,80,091/- (i.e. Rs.2,32,236/- towards PF and Rs.1,47,855/- towards ESI) belonging to the proprietorship is charged

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

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

reassessment was pending on the date of initiation of search under section 132 or making of requisition under section 132A, while computing the total income of the assessee under section 153A of the Act, additions or disallowances can be made only on the basis of the incriminating material found during the search or requisition. In the present case

DINESH BARANWAL,EAST CHAMPARAN vs. ITO, WARD-1(3), MOTIHARI

In the result, the appeal of the assessee is stand allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.593/Pat/2024 Assessment Year: 2012-13 Sri Dinesh Baranwal……………….....…..…………………....Appellant C/ M/S Salarpuria Jajodia & Co., 7, C. R Avenue, 3Rd Floor, Kol-72. [Pan: Adkpg6603N] Vs. Ito, Ward-1(3), Motihari…...……….…............................…..…..... Respondent Appearances By: Shri Siddharth Jhajharia, Fca, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 24 , 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Has Been Filed By The Assessee Against The Order Dated 24.05.2024 Passed By The Nfac For The Assessment Year 2012-13. 2. At The Outset, It Is Noted That There Is A Delay Of 57 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication. 3. Brief Facts Of The Case Are That The Assessee Was A Dealer Of A Telecom Service Operator, Namely M/S Unitech Wireless Tamil Nadu Pvt.

23, 2025 Date of pronouncing the order : July 24 , 2025 आदेश / ORDER Per Sonjoy Sarma, Judicial Member: This appeal has been filed by the assessee against the order dated 24.05.2024 passed by the NFAC for the Assessment Year 2012-13. 2. At the outset, it is noted that there is a delay of 57 days in filing the present appeal

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment is required to be made. The onus of filing of return of income on the assessee is a responsibility which is cast upon him to be fulfilled by him, if he fails to take benefit of any of the provisions I.T.A. Nos.: 181 & 182/PAT/2025 Assessment Year: 2017-18 Mahant Pandey. of law the assessee cannot plea that he will

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment is required to be made. The onus of filing of return of income on the assessee is a responsibility which is cast upon him to be fulfilled by him, if he fails to take benefit of any of the provisions I.T.A. Nos.: 181 & 182/PAT/2025 Assessment Year: 2017-18 Mahant Pandey. of law the assessee cannot plea that he will

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) &

23 undisclosed income protectively in both the appellant's hand and substantively in the hands of trust. A remand report was called for from the Assessing Officer regarding the merit and admissibility of the additional grounds taken by the appellant. Remand report in this group of cases dated 15.03.2021 duly forwarded by the JCIT (Central), Range-1, Patna was received

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) &

23 undisclosed income protectively in both the appellant's hand and substantively in the hands of trust. A remand report was called for from the Assessing Officer regarding the merit and admissibility of the additional grounds taken by the appellant. Remand report in this group of cases dated 15.03.2021 duly forwarded by the JCIT (Central), Range-1, Patna was received

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) &

23 undisclosed income protectively in both the appellant's hand and substantively in the hands of trust. A remand report was called for from the Assessing Officer regarding the merit and admissibility of the additional grounds taken by the appellant. Remand report in this group of cases dated 15.03.2021 duly forwarded by the JCIT (Central), Range-1, Patna was received

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) &

23 undisclosed income protectively in both the appellant's hand and substantively in the hands of trust. A remand report was called for from the Assessing Officer regarding the merit and admissibility of the additional grounds taken by the appellant. Remand report in this group of cases dated 15.03.2021 duly forwarded by the JCIT (Central), Range-1, Patna was received

RAMESHWARI AGRO SERVICES PRIVATE LIMITED,AURANGABAD vs. INCOME TAX DEPARTMENT, NFAC, DELHI

In the result, both appeals of the assessee are allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.187&188/Pat/2025 Assessment Year: 2017-18 & 2018-19 Rameshwari Agro Services Pvt. Ltd.…..…………………....Appellant C/O Lakshman Prasad & Kamlesh Kr. Yadav (Directors), Jai Gurudev Automobile, Gaya Road, Daudnagar, Aurangabad, Bihar-824113. [Pan: Aahcr9701K] Vs. Nfac, Delhi…………………….……….…............................…..…..... Respondent Appearances By: Shri Abhi Sarkar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 23, 2025 Date Of Pronouncing The Order : July 24, 2025 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Have Been Filed By The Assessee Against Separate Orders Dated 29.07.24 & 31.07.24 Passed By The Nfac ["Cit(A)"]. Since The Issues Involved In Ita Nos.187 & 188/Patna/2025 For The Assessment Years 2017-18 & 2018-19 Are Identical Except For Figures & Assessment Years, Both Appeals Are Heard Together & Are Being Disposed Of By This Common Order. For The Sake Of Convenience, The Facts Are First Taken From Ita No.187/Patna/2025. 2. Ita No. 187/Patna/ 2025 - A.Y. 2017-18 - Brief Facts Of The Case Are That The Assessee Did Not File Its Return Of Income For The Assessment

23, 2025 Date of pronouncing the order : July 24, 2025 आदेश / ORDER Per Sonjoy Sarma, Judicial Member: The captioned appeals have been filed by the assessee against separate orders dated 29.07.24 & 31.07.24 passed by the NFAC ["CIT(A)"]. Since the issues involved in ITA Nos.187 & 188/Patna/2025 for the Assessment Years 2017-18 and 2018-19 are identical except for figures