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26 results for “reassessment”+ Section 52clear

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Key Topics

Section 26368Section 153A68Section 143(3)34Section 25026Section 12714Limitation/Time-bar10Section 1478Revision u/s 2638Section 1487Addition to Income

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

ITA 25/PAT/2019[2010-11]Status: DisposedITAT Patna09 Aug 2019AY 2010-11

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.

For Appellant: Shri A.K.Rastogi & Rakesh Kumar, ARsFor Respondent: Shri Indrajeet Singh, DR
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148(1)Section 68

Showing 1–20 of 26 · Page 1 of 2

7
Condonation of Delay7
Section 376

reassessment proceedings. Accordingly, we reject this ground of assessee. 16. We also find that Hon’ble Supreme Court in the case of GKN Driveshafts (India) Ltd vs. ITO & Ors, 259 ITR 019 (SC) has held that when a notice under section 148 of the A.T.Act is issued, the proper course of action for the noticee is to file return

SUSHIL KUMAR KANODIA,PATNA vs. ACIT, CENTRAL CIRCLE-2, PATNA

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

reassessment under sections 148 & 147/148. In defense of his argument, the ld. AR relied on the decision of the coordinate bench in case of DCIT vs Shivali Mahajan in ITA No. 5585/DEL/2015 vide order dated 19.03.2019. 6. The ld. DR on the other hand, relied heavily on the order

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, PATNA vs. PATNA IRON PVT. LTD., PATNA

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

reassessment under sections 148 & 147/148. In defense of his argument, the ld. AR relied on the decision of the coordinate bench in case of DCIT vs Shivali Mahajan in ITA No. 5585/DEL/2015 vide order dated 19.03.2019. 6. The ld. DR on the other hand, relied heavily on the order

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. AJIT KUMAR, BETTIAH

In the result, the appeal filed by the Revenue is dismissed

ITA 239/PAT/2024[2017]Status: DisposedITAT Patna29 Sept 2025

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 143(3)Section 148Section 250Section 40A(3)Section 69

52,82,071/- holding that though the entries of the impounded documents were out of books I.T.A. No.: 239/PAT/2024 Assessment Year: 2017-18 Ajit Kumar. transactions of the assessee, the same were not claimed in the P&L A/c of the assessee. Hence, the provisions of section 40A(3) are not applicable. 2. That on the facts

SMT. RANJU KUMARI,JAMUI vs. INCOME TAX OFFICER, WARD- 2 (5), LAKHISARAI

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

ITA 339/PAT/2023[2017-18]Status: DisposedITAT Patna20 Nov 2024AY 2017-18

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 115BSection 144Section 147Section 148Section 250Section 69A

reassessment proceedings under section 148 of the Act, which is wrong, illegal and unjustified. 6. For that the learned CIT (A) has erred passing an ex-party order without allowing proper opportunity of being heard, which is wrong, illegal and unjustified in the facts and circumstances of the case. 7. That the whole order passed

SANTOSH KUMAR,AURANGABAD vs. ITO WARD- 3 (3), AURANGABAD

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

ITA 211/PAT/2023[2017-18]Status: DisposedITAT Patna12 Sept 2024AY 2017-18

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. No.211/Pat/2023 Assessment Year: 2017-18

Section 143(3)Section 147Section 148Section 250Section 69A

section 148 of the Act, which is wrong, illegal and unjustified in the facts and circumstances of the case. 7. That the whole order passed by the CIT(A) is bad in facts and law. That the appellant craves leave to add, alter, amend, or vary the above grounds of appeal at or before the time of hearing

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

ITA 335/PAT/2024[2018-19]Status: DisposedITAT Patna24 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

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

ITA 331/PAT/2024[2013-14]Status: DisposedITAT Patna24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

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

ITA 334/PAT/2024[2017-18]Status: DisposedITAT Patna24 Jul 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

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

ITA 330/PAT/2024[2012-13]Status: DisposedITAT Patna24 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

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

ITA 333/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

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

ITA 332/PAT/2024[2014-15]Status: DisposedITAT Patna24 Jul 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 37Section 80I

52,571/- on the account of expenses claimed in the profit and loss account for expenses made on account of corporate social responsibility (in short CSR) in Financial Year 2011-12 corresponding to Assessment Year 2012-13, notwithstanding the fact that the Explanation (2) of sub-Section (1) of Section 37 of the Act was inserted by the Finance

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 175/PAT/2023[2015-16]Status: DisposedITAT Patna13 May 2024AY 2015-16

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

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

52,53 and 54), GIB-06, GIB-07, GIB-08, GIB-09, GIB-10, GIB-11, GIB-12, GIB-13, GIB-14, GIB15 (only ledger page no. 50) and GIB-26 have been maintained and controlled by him in his personal capacity and in his own handwriting. 3. That keeping in view the above fact, the assessment order passed

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 176/PAT/2023[2016-17]Status: DisposedITAT Patna13 May 2024AY 2016-17

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

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

52,53 and 54), GIB-06, GIB-07, GIB-08, GIB-09, GIB-10, GIB-11, GIB-12, GIB-13, GIB-14, GIB15 (only ledger page no. 50) and GIB-26 have been maintained and controlled by him in his personal capacity and in his own handwriting. 3. That keeping in view the above fact, the assessment order passed

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 177/PAT/2023[2017-18]Status: DisposedITAT Patna13 May 2024AY 2017-18

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

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

52,53 and 54), GIB-06, GIB-07, GIB-08, GIB-09, GIB-10, GIB-11, GIB-12, GIB-13, GIB-14, GIB15 (only ledger page no. 50) and GIB-26 have been maintained and controlled by him in his personal capacity and in his own handwriting. 3. That keeping in view the above fact, the assessment order passed

GYAN INFRABUILD PVT. LTD,VARANASI vs. ACIT CENTRAL CIRCLE-03, PATNA

In the result, all the appeals of the assessee for Assessment Year

ITA 178/PAT/2023[2018-19]Status: DisposedITAT Patna13 May 2024AY 2018-19

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

For Appellant: Shri S.C. Aggrawal, Sr. Adv. & Shri Manish Rastogi, AdvFor Respondent: Md. A.H. Chowdhary, CIT, D/R
Section 132Section 133ASection 153ASection 263

52,53 and 54), GIB-06, GIB-07, GIB-08, GIB-09, GIB-10, GIB-11, GIB-12, GIB-13, GIB-14, GIB15 (only ledger page no. 50) and GIB-26 have been maintained and controlled by him in his personal capacity and in his own handwriting. 3. That keeping in view the above fact, the assessment order passed

VEENA DEVI,MUZAFFARPUR vs. PR.CIT-1, PATNA

In the result, appeal of the assessee is allowed

ITA 41/PAT/2021[2011-12]Status: DisposedITAT Patna06 Jun 2023AY 2011-12

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Dr. Manish Borad, Hon’Blei.T.A. No. 41/Pat/2021 Assessment Year: 2011-12 Veena Devi Pr. Cit, Patna-1 Vs Krishnapuri, Nh 28 Bhagwanpur Chowk Muzaffarpur - 842001 [Pan: Aoyps8291P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ashish Maskara, Advocate Revenue By : Smt. Rinku Singh, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 29/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 06/06/2023 आदेश/O R D E R Per, Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax, Patna-1, (Hereinafter The “Ld. Pr. Cit”) Dt. 23/03/2021, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2011-12. 2. The Registry Has Pointed Out That There Is A Delay Of Eighteen (18) Days In Filing Of This Appeal In Time Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Stating The Reasons Of Delay. After Perusing The Same, We Find That The Assessee Was Prevented By Sufficient Cause From Filing The Appeal In Time Before The Tribunal. Hence, The Delay Is Condoned & The Appeal Is Admitted. 3. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Order Passed U/S 263 Of The It Act By The Ld Pcit, Patna Is Wrong, Illegal, Arbitrary & Against The Fact & Circumstances Of The Case.

For Appellant: Shri Ashish Maskara, AdvocateFor Respondent: Smt. Rinku Singh, CIT, D/R
Section 143(3)Section 147Section 148Section 250Section 263

reassessment proceeding U//s 147 of the IT Act and no addition was made by the AO as such AO has no jurisdiction to assess any other income. 5. For that the Learned PCIT should have appreciated the fact and law that it has been decided by apex court that "if in the course of proceeding

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

ITA 630/PAT/2024[2016-17]Status: DisposedITAT Patna15 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)(c)

reassessment done thereafter are totally based on presumptions /assumptions of the learned Assessing Officer and the assessment made on the assumptions and presumption of fact and on conjectural estimates and hypothetical basis having no relation with the monetary transaction entries in such pattern in the accounts of both the parties i.e. the land owner & the developer for capital gain

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

ITA 323/PAT/2024[2015-16]Status: DisposedITAT Patna12 Sept 2024AY 2015-16

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

Section 127Section 143(3)Section 153ASection 263

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

ITA 327/PAT/2024[2019-20]Status: DisposedITAT Patna12 Sept 2024AY 2019-20

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

Section 127Section 143(3)Section 153ASection 263

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