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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT (CENTRAL), PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

NALANDA ENGICON PVT. LTD, PATNA,PATNA vs. PR. CIT CENTRAL, PATNA

In the result, all the appeals of the assessee are allowed as per terms indicated hereinabove

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.322 To 329/Pat/2024 Assessment Years: 2014-15 To 2021-22

Section 153A for assessments in the case of search or acquisition, Section 153B for time limit for completion of assessment u/s 153A, Section 153C for assessment of income of any other person and Section 153D i.e., prior approval necessary for assessment in case of search or acquisition. So far as Section 153D of the Act is concerned, the same reads

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

2 is that the order of ld. PCIT is barred by limitation under the Act as the period of two years under section 263(1) of the Act is to be reckoned from the date of original assessment framed under section 143(3) dated 31.03.2016 and not from the dated reassessment

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

2 is that the order of ld. PCIT is barred by limitation under the Act as the period of two years under section 263(1) of the Act is to be reckoned from the date of original assessment framed under section 143(3) dated 31.03.2016 and not from the dated reassessment

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.

2) of the Act is a jurisdictional pre-condition to finalizing the reassessment. (iv) The onus is on the Revenue to show that proper service of notice has been effected under Section 148 of the Act on the Assessee or an agent duly empowered by him to accept notices on his behalf. In the present case the Revenue has failed

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

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

2), the time taken in giving an opportunity to the assessee to be reheard under the proviso to section 129 and any period during which any proceeding under this section is stayed by an order or injunction of any court shall be excluded." 13. A bare perusal of sub section-1 would reveal that powers of revision granted by section

DOLLY GHOSH,BHAGALPUR vs. ACIT CENTRAL CIRCLE 1 PATNA, PATNA

In the result, the appeal of the assessee is allowed

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

2) of sections 271D and 271E. 11 Assessment Year: 2012-2013 Dolly Ghosh 10. The time limit for imposing penalties under Chapter- XXI have been provided in section 275 of the Income Tax Act. Sub-clause (1) of this section starts with: No order imposing a penalty under this Chapter shall be passed