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

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

unexplained investment in purchases out of books. The appellant has vehemently objected to this finding. The appellarit has submitted that its premises as well as that of directors were covered in search. Not an iota of unrecorded purchases/investment was found from any premises. Moreover, whilم making assessment, the AO had accepted ITA Nos. 373, 332& 237/PAT/2025 Patna Iron

PATNA IRON PVT. LTD.,PATNA vs. ACIT, CENTRAL CIRCLE-2, PATNA

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

unexplained investment in\npurchases out of books. The appellant has vehemently objected to this finding.\nThe appellarit has submitted that its premises as well as that of directors were\ncovered in search. Not an iota of unrecorded purchases/investment was found\nfrom any premises. Moreover, while making assessment, the AO had accepted\n\nPage 4\n\nITA Nos. 373, 332& 237/PAT/2025

MADHU DEVI,NAWADA vs. ITO, WARD 2 (3), BIHARSHARIF, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment proceeding in question is amount to review and based on change in opinion which is not permissible under the income tax act, as such, whole of the proceeding of re-assessment is bad and illegal and order passed on such illegal proceeding is also bad and without jurisdiction. 3. For that the order under challenge is otherwise

MANOJ KUMAR DAS,BEGUSARAI vs. ASSESSMENT UNIT INCOME TAX DEPARTMENT, DELHI

Appeal is allowed for statistical purposes

Bench: 19/07/2025. The Appeal Is Delayed By Around 37 Days. 4. That The Assessee States That The Reason For Delay Is That The Assessee Is Suffering From Hiv Aids & Is Constantly Under Treatment. Copy Of Medical Treatment Is Enclosed.

unexplained investment in purchase of property credited from undisclosed sources u/s 68 read with section 115BBE of the Act and assessed the same under the Act. 10. For that the Id. assessing officer has grossly erred in holding the entire cash deposits as undisclosed income, notwithstanding the fact that it was apparent from the bank statement itself that purchases have

RANJEET KUMAR (INDIVIDUAL),BEGUSARAI vs. INCOME TAX OFFICER, WARD- 2 (1), BEGUSARAI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Unexplained investments in immovable property. 9. For that the Ld. CIT(A) has erred in upholding the order passed by the Ld. A.O as the initiation of reassessment

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

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

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

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

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA vs. ACIT CIRCLE-2, PATNA

The appeals of the assessee are allowed for statistical purposes

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

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

MERIDIAN CONSTRUCTION INDIA LIMITED,PATNA, BIHAR vs. ACIT CIRCLE-2 PATNA, PATNA

The appeals of the assessee are allowed for statistical purposes

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

unexplained expenditure incurred by the assessee for construction of three real estate properties, i.e. Patna One Mall, Boring Road Project and Phulwarisharif Patna Project. The assessee has sold the properties in these assessment years. The details of those properties have been tabulated in the assessment orders. The ld. Assessing Officer found that sale considerations disclosed by the assessee are lower

SHANKAR CONSTRUCTION,PANCHGACHIA vs. ITO, WARD-3(1), PURNEA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumari.T.A. No. 565/Pat/2024 Assessment Year: 2016-2017 Shankar Construction,………………..…….……Appellant Panchgachia, Panchgachia-852124, Bihar [Pan:Abofs0800R] -Vs.- Income Tax Officer,………………….……..……Respondent Ward-3(1), Purnea, Bihar Appearances By: Shri S.K. Tulsiyan, Advocate, Appeared On Behalf Of The Assessee Shri Ashok Kumar, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: October 22, 2024 Date Of Pronouncing The Order: November 18, 2024 O R D E R

investments in the form of securities premium to M/s New KMS. These companies are mainly paper companies. During the year under consideration M/s Shanker Construction had received unsecured loan of Rs. 50,90,740/- during the financial year 2015-16. As M/s New KMS is showing very meager income and it does not have any activity to support the huge

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, PATNA, C.R. BUILDING, PATNA vs. DEEPSHREE PROPERTIES PVT. LTD., SAGUNA KHAGAUL DANAPUR PATNA

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

Bench: SHRI DUVVURU RL REDDY, VICE PRESIDENT SHRI SANJAY AWASTHI (Accountant Member)

investments amounting to Rs. 2.5 Crores were allegedly made in the assessee company and the same were not recorded in the books of account. This fact was admitted by Mr. Satyendra Kumar, Accountant during the course of statement under oath recorded during the course of survey operation. This amount was added u/s 69A of the Act. 2. Aggrieved with this

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

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

unexplained expenditure of Rs. 8,26,46,443/- shall not be a ground of initiating the proceeding under the section 153A beyond the period of six years, thereby making the order under section 153A/143(3) as well as order under the section 263 invalid, illegal and arbitrary. 10. For that on the fact and in circumstances of the case

AMAR KASERA (HUF),PATNA vs. ACIT CENTRAL CIRCLE-1, PATNA

In the result, all the captioned appeals of the assessee stand allowed

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

reassessment order passed u/s. 147 of the Act is hereby quashed. ITA No. 180/Pat/2023 (AY 2013-14): 13. Both the Ld. Representatives of the parties have submitted that all the facts and issues involved in this appeal are identical to the above discussed assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12. The identical legal grounds have been taken