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 proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

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 proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

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 proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

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 proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

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 proceeding and passing order u/s 147 of the Act, notwithstanding the fact that the assessment for the Assessment Year 2013-14 was already completed u/s 143(3) of the Act vide order of assessment dated 31/03/2016 and that an assessment concluded u/s 143(3) of the Act cannot be reopened u/s 148 of the Act after the expiry

KISHORI CAPITAL MARKETS PVT. LTD.,BBD BAGH (EAST) vs. ITO WARD 2(1), PATNA, LOK NAYAK BHAWAN

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

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

80,140/-. The case of the assessee was selected for scrutiny u/s 143(3) of the Act, a notice u/s 143(2) of the Act was issued and served on the assessee by ITO, Ward-2(1), Patna. The learned AO after going over the documents filed by the assessee in support of the claim made by the assessee

PAVAN KUMAR BHAGAT,SAHARSA vs. ITO, WARD-3(4), SAHARSA, SAHARA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment proceeding under Section 147 of the Act and has grossly acted in violation of the directions of the Hon'ble Supreme Court in the case of GKN Driveshafts (India) Ltd vs ITO reported in [2002] 125 Taxman 963 (SC) and [2003] 259 ITR 19 (SC). 10. For that the Ld. Assessing officer has erred not serving any notice u/s

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

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

147, as the case may be, has been paid within the period specified in such notice of demand; and ITA Nos.163 to 166,170&172/PAT/2023 Nand Kumar Prasad & Biswanath Prasad; A.Ys. 2017-18 to 2020-21 (b)no appeal against the order referred to in clause (a) has been filed. (2) An application referred to in sub-section (1) shall

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

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

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

147 can only be initiated if income chargeable to tax has escaped assessment due to the assessee’s failure to fully and truly disclose all the material facts necessary for the reassessment. As per the assessment order the AO issued notice u/s 142(1) of the Act seeking details of loan transaction and assessee submitted all the relevant documents

SAROJ BALA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

147 taxmann.com 288/[2022] SCC Online All\n1294], the Hon'ble High Court has held that approval u/s.153D of the Act\nis to be granted by the competent authority on the draft assessment order\nfor each year separately. The operative part of the said judgment is\nextracted below :-\nConsidering the submissions of the learned counsel for the parties\nand having

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

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

u/s,153A based on the report from the Investigation wing of the department, but at the same time has to be backed by independent enquiry by the AO with positive evidence to corroborate the findings contained in the investigation report. However the AO failed to gather an iota of additional evidence or could controvert the evidence placed by the appellant

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

80,091/- (i.e. Rs.2,32,236/- towards PF and Rs.1,47,855/- towards ESI) belonging to the proprietorship is charged to the company. In view of this fact, the AO had disallowed the aforesaid amount of Rs.3.80.001/- for the year under consideration and added it to the total income of the assessee-company, 5.2. Further, during the appellate proceedings

BHOLA PRASAD YADAV,PATNA vs. INCOME TAX OFFICER, WARD- 4(1), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

80,250/-, by making additions as detailed under: (the details are mentioned in the form of a chart) 3. For that the learned NFAC has erred in the facts and circumstances of the case in confirming the action of the AO in making addition of Rs 43,46,500/- on account of alleged cash deposit made in IDBI Bank account