ACIT, CENTRAL CIRCLE-3, PATNA, PATNA vs. SMT. SIPRA GUPTA, PATNA

8: For that, addition of Rs.12163000 under section 68 is lead in law\nin absence of any reasonable opportunity of being heard. The whole assessment is in\nviolation of natural law and justice and void ab initio.\nFor that Ld. A.O. has failed to appreciate the stand taken initially by the appellant that\nthe entire deposit in the bank

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

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

13 of the notice issued under the section 142(1) of the Act. 15. For that on the fact and in circumstances of the case, the Pr. CIT has erred in applying the sub-section (a) and (b) of the explanation - 2 of the section 263 of the Act as the order of assessment under the section

MITHILESH KUMAR,PATNA vs. DCIT CENTRAL CIRCLE-2, PATNA

In the result, the appeal of the assessee is allowed

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

68 to 69D read with Section 115BBE, by colouring the "deemed incomes" as business income. More so, in cases of unaccounted cash and undisclosed investment/expenditure in purchases, and excess stock assessable under section 69A/69B/69C of the Act. 3.2.1. At the outset, all the decisions quoted and relied upon by the assessee, with regard to non-applicability of Section

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

13 and 14] [In favour of assessee]” iii) PCIT Vs. Sandip Kumar Parsottambhai Patel 457 ITR 368 (Gujarat) 07/03/2023 “Where Assessing Officer treated transactions in purchase and sale of share as sham transactions and sale proceeds of shares were treated as undisclosed income under section 68, since payments were received through account payee cheques and transactions were done through

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

13 and 14] [In favour of assessee]” iii) PCIT Vs. Sandip Kumar Parsottambhai Patel 457 ITR 368 (Gujarat) 07/03/2023 “Where Assessing Officer treated transactions in purchase and sale of share as sham transactions and sale proceeds of shares were treated as undisclosed income under section 68, since payments were received through account payee cheques and transactions were done through

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

13 and 14] [In favour of assessee]” iii) PCIT Vs. Sandip Kumar Parsottambhai Patel 457 ITR 368 (Gujarat) 07/03/2023 “Where Assessing Officer treated transactions in purchase and sale of share as sham transactions and sale proceeds of shares were treated as undisclosed income under section 68, since payments were received through account payee cheques and transactions were done through

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

13 and 14] [In favour of assessee]” iii) PCIT Vs. Sandip Kumar Parsottambhai Patel 457 ITR 368 (Gujarat) 07/03/2023 “Where Assessing Officer treated transactions in purchase and sale of share as sham transactions and sale proceeds of shares were treated as undisclosed income under section 68, since payments were received through account payee cheques and transactions were done through

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

13 and 14] [In favour of assessee]” iii) PCIT Vs. Sandip Kumar Parsottambhai Patel 457 ITR 368 (Gujarat) 07/03/2023 “Where Assessing Officer treated transactions in purchase and sale of share as sham transactions and sale proceeds of shares were treated as undisclosed income under section 68, since payments were received through account payee cheques and transactions were done through

I.T.O. vs. M/S KUMAR CONSTRUCLTION,

In the result, the appeal of the Revenue is partly allowed

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

8% of the gross receipts, which worked out to a profit of Rs.77,68,919/-. The Revenue is aggrieved with this exercise and emphasized that ld. Assessing Officer has made specific disallowances under sections 40A(3) and 40(a)(ia) of the Income Tax Act. A perusal of the assessment order would indicate that to some extent, the exercise

ACIT vs. INTERNATIONAL SCHOOL OF SOCIAL WELFARE HUMAN RESOURCES,

In the result, the appeal filed by the Revenue is allowed while the Cross Objection filed by the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

13,93,625/- and Rs. 16,68,523/- as 'Advance to Landlord'. At the same time, the Society has paid Rs. 18,00,000/- as rent (to the landlords). The landlords in question are also the members of the Society or their family members. Thus, the assessee -Society is directly passing the benefits to its members. The Society is, therefore

M/S MARUTI NANDAN FOOD PRODUCTS PVT LTD,PATNA vs. ITO, WARD- 2(1), PATNA

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

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2013-14

section 68 of the Act. She further stated that even in the affidavits/confirmations submitted by nine lenders out of the total eighteen lenders, no details in respect of their PAN, ITR, Balance Sheet were furnished so as to enable the Ld. AO to carry out appropriate verification and examination of the loan transactions. She further submitted that

ACIT, CENTRAL CIRCLE-2, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

68,566/- to the income of the assessee in assessment framed u/s 143(3) of the Act dated 31.03.2016 on the basis that according to rent controller order , the revised rent is effective from 27.07.2012. 4. In the appellate proceedings, the Ld. CIT(A) simply dismissed the appeal of the assessee by upholding the order of AO. 5. After hearing

KUMAR ARUNOSAYA,PATNA vs. A.O., CIRCLE-6, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

68,566/- to the income of the assessee in assessment framed u/s 143(3) of the Act dated 31.03.2016 on the basis that according to rent controller order , the revised rent is effective from 27.07.2012. 4. In the appellate proceedings, the Ld. CIT(A) simply dismissed the appeal of the assessee by upholding the order of AO. 5. After hearing