RANJEET SINGH,PATNA vs. ITO, WARD- 5 (5), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

unexplained. In the instant case was reopened u/s 147 of the income tax Act 1961. A notice u/s 148 dated 01.08.2018 has been alleged to have been served on the assessee. But such notice was neither served on appellant on any occasion nor intimated regarding issuance of such notice to the appellant even after lapse almost nine months. The department

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

unexplained cash credit under section 68 read with section 115BBE of the Act and assessed the same under the Act. I.T.A. No.: 321/PAT/2025 Assessment Year: 2015-16 Zaimur Rahman. 11. For that the ld. Commissioner of Income Tax (Appeal) as well as the ld. assessing officer, without giving any opportunity, much less sufficient opportunity, has erred in holding that Rs.11

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

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

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

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

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

ARCHANA,PATNA vs. ITO, WARD- 4 (1), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

reassessment proceeding has been initiated for making roving and fishing enquiry. The order of assessment as sustained u/s 147 rws 144 rws 144B is arbitrary, unjustified, without jurisdiction, void ab-initio, bad in law, vitiated in law and invalid. The order as passed u/s 147 is fit to be quashed / cancel / annulled. 1.2 For that the order of the assessment

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

cash withdrawn is for carry out departmental work. there is no specific contract I am government servant and worked as per the direction of superior officer as I was intrusted in carry out the departmental work it is not business receipts. DETAILS OF DEPARTMENTAL WORK CARRIED OUT AND CREDITED TO BANK ACCOUNT IS ATTACHED AS PER ANNEXURE

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

cash withdrawn is for carry out departmental work. there is no specific contract I am government servant and worked as per the direction of superior officer as I was intrusted in carry out the departmental work it is not business receipts. DETAILS OF DEPARTMENTAL WORK CARRIED OUT AND CREDITED TO BANK ACCOUNT IS ATTACHED AS PER ANNEXURE

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

147 of the Act. Merely because the revenue classifies a fact already on record as “information” may vest it with the power to issue a notice of re assessment u/s 148A(b) but would certainly not vest it with the power to issue a re-assessment notice u/s 148 post an order u/s 148A(d). As per clause

A V ISPAT PRIVATE LIMITED,PATNA vs. ACIT CENTRAL CIRCLE 2 PATNA, PATNA

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

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No. 222/Pat/2023 Assessment Year: 2014-15 Av Ispat Private Limited Acit, Central Circle-2 Agamkuan, Patna-800007 Patna-800001, Bihar Vs Bihar [Pan: Aaca9469P] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent) Assessee By : None Revenue By : Ashwani Kumar, Dr सुनवाई की तारीख/Date Of Hearing : 05.09.2024 घोषणा की तारीख /Date Of Pronouncement : 30.10.2024 आदेश/O R D E R Per Dr. Manish Borad: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Commissioner Of Income-Tax (Appeals) [Learned Cit (A)] Dated 28.04.2023, Which Is Arising Out Of The Assessment Order Under Section 143(3) Of The Income-Tax Act, 1961 (The Act) Dated 14Th March, 2022. 2. When The Case Was Called For, None Appeared On Behalf Of The Assessee. We Observe That On The Previous Occasions When The Case Was Fixed For Hearing On 29Th July, 2024 & 30Th July, 2024, None Appeared. However, Considering The Smallness Of The Issue & That The Facts Were Available On Record, It Was Decided To Adjudicate These Appeals With Assistance Of Learned Departmental Representative. Assessee Has Raised Following Grounds Of Appeal: - “1. The Order Passed By Learned Cit(A)-3, Patna Is Unjust, Unwarranted & Bad In Law.

147 of the act for disturbing the settled position. 4. On the facts and in the circumstances of the case, the ld CIT(A)-3, Patna erred in confirming the wrongful quantification of a sum of Rs 25,00,084/- being the amount of unsecured loan received by the appellant. 5. On the facts and in the circumstances

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

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

credit. Apart from this addition, he further observed that a document inventorized as GIB- 12, page no. 8 recovered during the search conducted on Subhash Prasad Yadav Group cases. A perusal of this document would reveal that a sum of Rs.5,50,00,000/- has been transferred to Shri Sanjay Singh (PAN has been given by the ld. Assessing Officer

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

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

credit. Apart from this addition, he further observed that a document inventorized as GIB- 12, page no. 8 recovered during the search conducted on Subhash Prasad Yadav Group cases. A perusal of this document would reveal that a sum of Rs.5,50,00,000/- has been transferred to Shri Sanjay Singh (PAN has been given by the ld. Assessing Officer

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

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

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

u/s. 147 of the Act. In the course of the reassessment proceedings though the assessee remained non-compliant on most of the occasions but after repeated notices he provided details about the cash and credit entries appearing in his bank account held with PNB Bank being account no. 3861008700001 and gave a break up about the cash deposited during

AMRENDRA PRATAP SINGH,VARANASI vs. INCOME TAX OFFICER WARD- 3(1), GAYA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

unexplained income u/s 69A of the Act and I.T.A. No.: 101/PAT/2025 Assessment Year: 2012-13 Amrendra Pratap Singh. assessed the same under Section 115BBE of the Act, solely on the basis of some information shared by the Assistant Director of Income Tax (Inv.), Unit- 1, Varanasi, notwithstanding the fact that the said amount was from sale of ancestral agricultural land

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

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

reassessment under sections 148 &\n147/148. In defense of his argument, the Id. AR relied on the\ndecision of the coordinate bench in case of DCIT vs Shivali Mahajan\nin ITA No. 5585/DEL/2015 vide order dated 19.03.2019.\n\n6.\nThe Id. DR on the other hand, relied heavily on the order of Id. AO\nand