SANTOSH KUMAR KESHRI,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 226/Pat/2024 Assessment Year: 2017-2018 Santosh Kumar Keshri,………..…….…………Appellant Shop No. 3, Jaiswal Market, Sabji Mandi, Mithapur-800001, Bihar [Pan:Asapk1127E] -Vs.- Assistant Commissioner Of Income Tax,...Respondent Dc/Ac Circle-6, Patna-800001, Bihar Appearances By: Shri Supriya Sharma, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 19, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

33,34,122/- after addition of deposits made during demonetization period and sundry creditors without going consideration the books of account, which was provided by the assessee. The Ld. A.O. has done another addition of Rs.58,62,495/- considering the figure of Sundry Creditors on the contention that figure has increased from Rs.65,987 (FY 2015- 16) to Rs.58

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

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 account in between 09.11.2016 amounting to\nRs.11230000

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

ACIT, CIRCLE-4, 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 ARUNODAYA,PATNA vs. ASSISTANT COMMISSIONER OF INCOME TAX - 6, PATNA [NEW – DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE – 2, PATNA], 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

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

DCIT, CIRCLE-4, 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

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

33 of the Indian Income-tax Rules, 1922, for the purpose of computing the income of a nonresident even if the ITO had not done so in the assessment proceedings. In CIT v. Kanpur Coal Syndicate [1964] 53 ITR 225 , a three- judge Bench of this Court discussed the scope of section

PIONEER EDUCATION SOCIETY,HARYANA vs. ITO, PATNA

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 405/Pat/2024 Assessment Year: 2016-2017 Pioneer Education Society,……….…….....……Appellant C-310/311, Unitech Business Zone Nirvana Country, South City-Ii, Sector-50, Haryana, Pin Code No.122018 [Pan:Aadap0174C] -Vs.- Income Tax Officer,……………………………….Respondent Ward-1(1), Patna, Lok Nayak Jai Prakash Bhawan, New Dak Bunglow, Patna-800001, Bihar Appearances By: Shri Yatin Sharma, Advocate, Appeared On Behalf Of The Assessee Rinku Singh, Cit (Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 21, 2025 Date Of Pronouncing The Order: April 24, 2025 O R D E R

section 68 of the Act and added to the total income of the assessee. Therefore, the total addition comes to Rs.4,07,90,320/- (Rs.10,55,000/- plus Rs.3,97,35,320/-). 2.1. In support of rent debited in the income & expenditure account to the tune of Rs.3,43,84,722/-, the assessee furnished copy of three Memorandum

BABULAL PRASAD SUJIT KUMAR,MUZAFFARPUR vs. ACIT, CENTRAL CIRCLE, MUZAFFARPUR

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

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 276/Pat/2022 Assessment Year: 2018-2019 Babulal Prasad Sujit Kumar,……………….…Appellant Purani Bazar, Muzaffarpur-842001, Bihar [Pan:Aalfb9242J] -Vs.- Assistant Commissioner Of Income Tax,.….Respondent Central Circle-Muzaffarpur, Chabdralok Bhawan, Near Chandralok Market, Naya Tola, Muzaffarpur-842002, Bihar Appearances By: Shri A.K. Rastogi, Sr. Advocate & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 26, 2024 Date Of Pronouncing The Order: December 30, 2024 O R D E R

section 68 of the I.T. Act, 1961. (ii) That on the facts and circumstances of the case, the CIT(Appeals) has erred in sustaining the addition of Rs.5,03,565/- being the difference between the cash found on the date of survey amounting to Rsa.7,36,950/- minus sales made in cash estimated on ad hoc basis at Rs.2

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

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.11,43,600 shown

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

68 "it was necessary for the assessee to prove prima facie the Page 8 of 19 I.T.A. No.: 304/PAT/2024 Assessment Year: 2017-18 Ranjeet Singh. identity of creditors, the capacity of such creditors and lastly the genuineness of transactions". 8.4 Similarly, in the case of CIT v. Precision Finance (P.) Ltd [1994] 208 ITR 465 (Cal)], it was observed that

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

33 PM SELL 1 114.85 5000 574250.00 0 NICKEL FUTURES 16/03/201101:28:41 PM SELL 1 114.25 5000 571250.00 0 ZINC FUTURES 21/03/2011 03:57:32 PM SELL 1 113.65 5000 568250.00 0 ZINC FUTURES 21/03/2011 03:58:50 PM SELL 10 113.20 5000 5660000.00 2 ZINC FUTURES 21/03/201103:59:16 PM SELL 11 113.20 5000 6226000.00 13 ZINC FUTURES

PRERNA AGENCY PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER, WARD 2(2), PATNA

In the result, the appeal of the assessee is allowed

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

33,000/- in his bank account maintained with HDFC. On being asked to explain the source of the said cash deposit it was informed to the Ld. AO that the deposits represented opening cash balance (as on 01.04.2016) and cash withdrawals made from time to time. The Ld. AO has depicted in tabular form at pages

WASEEM ALAM,WEST CHAMPARAN vs. ITO, NATIONAL E ASSESSMENT CENTRE, DELHI

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.17/Pat/2025 Assessment Year: 2018-19 Waseem Alam…...………………….....…..…………………....Appellant Bhawanipur Kursi Barawa, Sikta, West Champaran, Bihar-845307. [Pan: Alopa0369B] Vs. Ito, Nfac, Delhi…………..……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 17, 2025 Date Of Pronouncing The Order : July 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.9,68,550. The Return Was Processed Under Section 143(1) Of The Act. Subsequently, The Case Was Selected For Limited Scrutiny Under The E- Assessment Scheme, With The Specific Issue Of Verification Of Large Deduction Claimed Under Section 57 Of The Act. Notice Under Section 143(2) & Subsequently Under Section 142(1) Was Issued To The Assessee. Although The Assessee Uploaded Certain Documents Electronically In Response, The Details Were Found To Be Incomplete. The

68,234 under various heads: Rs.30,00,000 from contract work, Rs.182000/- from dairy income, Rs.16,33,540 from transport income, Rs.16,50,000 from hostel rent and the assessee had claimed expenses of Rs.58,83,717 under 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

68 (Bom) and (1984) 31 ITD 52 (SB-Delhi) holding that in an assessment made u/s 143(3) it should be presumed that the assessment u/s 143(3) had been made after proper application of mind and also holding that the assessee has no control over the way, the assessment is drafted by the AO and generally issues which

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

68 (Bom) and (1984) 31 ITD 52 (SB-Delhi) holding that in an assessment made u/s 143(3) it should be presumed that the assessment u/s 143(3) had been made after proper application of mind and also holding that the assessee has no control over the way, the assessment is drafted by the AO and generally issues which

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

68 (Bom) and (1984) 31 ITD 52 (SB-Delhi) holding that in an assessment made u/s 143(3) it should be presumed that the assessment u/s 143(3) had been made after proper application of mind and also holding that the assessee has no control over the way, the assessment is drafted by the AO and generally issues which