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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction on 'Other Income' claimed u/s 801A: ₹66,47,34,169/- The total income of the assessee was thus assessed

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction on 'Other Income' claimed u/s 801A: ₹66,47,34,169/- The total income of the assessee was thus assessed

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction on 'Other Income' claimed u/s 801A: ₹66,47,34,169/- The total income of the assessee was thus assessed

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 was completed u/s 143(3) r.w.s 147 of the Act on 02.08.2016 by making the following additions/disallowances: (a) Corporate Social Responsibility u/s 37(1) of the Act: ₹30,52,571/- (b) Interest on TDS: ₹46,190/- (c) Deduction on 'Other Income' claimed u/s 801A: ₹66,47,34,169/- The total income of the assessee was thus assessed

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

91,042/- declared in e-return filed on 01-10-2009 u/s. 139(1) of the Act. The assessee declared 0.39% net profit on gross contract receipts of Rs.7,14,03,035/-. The case was selected for scrutiny through CASS with the reason “to examine various aspects of contractors (excluding transporters) business and the genuineness of Sundry Creditors”. Notice u/s

ARUN CONSTRUCTION,BHAGALPUR vs. ACIT, CIRCLE-1, BHAGALPUR

In the result, all the appeals (ITA Nos

91,042/- declared in e-return filed on 01-10-2009 u/s. 139(1) of the Act. The assessee declared 0.39% net profit on gross contract receipts of Rs.7,14,03,035/-. The case was selected for scrutiny through CASS with the reason “to examine various aspects of contractors (excluding transporters) business and the genuineness of Sundry Creditors”. Notice u/s

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]

91,930/-. Notice u/s 143(2) was issued to the assessee on 06.07.2021 and on request of the assessee copy of the reason recorded for reopening along with Section 151 of the Act was provided to the assessee. The assessee filed objection and also filed copy of financial statement, ledger copy of Rashidhan Traders Pvt. Ltd., copy of MCA details

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

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

91 ITR (Tribunal) 682\n7.\nPr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM\nApplication No. 28994/2024 as reported in Taxsutra 343-HC-\n2024-Delhi.\n8.\nPr. CIT vs. Anuj Bansal [ITA 368/2023]\n9.\nSmt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021)\n10.\nHon'ble Allahabad High Court in the case of Pr. CIT vs.\nSapna

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

In the result, appeal of the assessee is allowed

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.

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 U/s 147

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

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

91 ITR (Tribunal) 682\n7.\nPr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM\nApplication No. 28994/2024 as reported in Taxsutra 343-HC-\n2024-Delhi.\n8.\nPr. CIT vs. Anuj Bansal [ITA 368/2023]\n9.\nSmt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021)\n10.\nHon'ble Allahabad High Court in the case of Pr. CIT vs.\nSapna

MURLIDHAR PRASAD,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

91 ITR (Tribunal) 682\nPr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM\nApplication No. 28994/2024 as reported in Taxsutra 343-HC-\n2024-Delhi.\nPr. CIT vs. Anuj Bansal [ITA 368/2023]\nSmt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021)\nHon'ble Allahabad High Court in the case of Pr. CIT vs.\nSapna Gupta\nACIT vs. Sirajuddin

DY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 PATNA, PATNA vs. LOVELY RANI CONSTRUCTION PRIVATE LTD , PATNA

91 ITR (Tribunal) 682\n7.\nPr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM\nApplication No. 28994/2024 as reported in Taxsutra 343-HC-\n2024-Delhi.\n8.\nPr. CIT vs. Anuj Bansal [ITA 368/2023]\n9.\nSmt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021)\n10.\nHon'ble Allahabad High Court in the case of Pr. CIT vs.\nSapna

ANIL KUMAR,WEST CHAMPARAN vs. ITO, WARD- 1 (5), BETTIAH

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

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

u/s 144/147 and penalty order under section 271(1)(c) of the Act, dated 21.12.2017 and 30.05.2018, respectively. Since the issues in both the appeals are related to the same assessee, both the appeals were heard together and I.T.A. Nos.: 261 & 262/PAT/2025 Assessment Year: 2014-15 Anil Kumar. are being decided vide this common order for the sake of convenience

ANIL KUMAR,WEST CHAMPARAN vs. ITO, WARD- 1 (5), BETTIAH

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

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

u/s 144/147 and penalty order under section 271(1)(c) of the Act, dated 21.12.2017 and 30.05.2018, respectively. Since the issues in both the appeals are related to the same assessee, both the appeals were heard together and I.T.A. Nos.: 261 & 262/PAT/2025 Assessment Year: 2014-15 Anil Kumar. are being decided vide this common order for the sake of convenience

LOVELY RANI CONSTRUCTIONS PRIVATE LIMITED,PATNA vs. ASSISTANT COMMISSIONER OF INCOME, PATNA

91 ITR (Tribunal) 682\n7.\nPr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM\nApplication No. 28994/2024 as reported in Taxsutra 343-HC-\n2024-Delhi.\n8\nPr. CIT vs. Anuj Bansal [ITA 368/2023]\n9.\nSmt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021)\n10.\nHon'ble Allahabad High Court in the case of Pr. CIT vs.\nSapna

ITO, WARD-2(1), PATNA vs. M/S SUN COMTECH PVT LTD, PATNA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

147 of the Act because at the time of assessment, the Ld. AO had already verified all the points during the previous assessment done u/s 143(3) of the Act, which were being raised during the course of the reassessment proceeding. The assessee relied upon the judicial pronouncements in the case of Income-tax Officer vs. Lakhmani Mewal

MURLIDHAR PRASAD,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

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

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

91 ITR (Tribunal) 682 7. Pr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM Application No. 28994/2024 as reported in Taxsutra 343-HC- 2024-Delhi. 8 Pr. CIT vs. Anuj Bansal [ITA 368/2023] 9. Smt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021) 10. Hon'ble Allahabad High Court in the case of Pr. CIT vs. Sapna

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1,PATNA, PATNA vs. MURLIDHAR PRASAD, PATNA

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

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

91 ITR (Tribunal) 682 7. Pr. CIT vs. Shiv Kumar Nayyar in ITA No. 285/2024 and CM Application No. 28994/2024 as reported in Taxsutra 343-HC- 2024-Delhi. 8 Pr. CIT vs. Anuj Bansal [ITA 368/2023] 9. Smt. Sapna Gupta, Kanpur vs DCIT Lucknow ITAT (2021) 10. Hon'ble Allahabad High Court in the case of Pr. CIT vs. Sapna