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

section 68, where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not satisfactory in the opinion of the A.O., the sum so credited may be charged to Income Tax as the income

THE SIWAN CENTRAL CO.-OPERATIVE BANK LTD,SIWAN vs. DCIT, CIRCLE-2, MUZAFFARPUR

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

Bench: Sri Rajpal Yadav & Dr. Manish Borad

section 36(viia) of the I.T. Act whereas the entire bad debt is an allowable deduction. 11. For that the Ld. CIT(A) has erred in upholding addition of Rs.2,88,460/- on the ground that the same is on account of income tax. 12. For that the disallowance of Rs. 1,40,675/- and additions of Rs.3,68

THE SIWAN CENTRAL CO.-OPERATIVE BANK LTD,SIWAN vs. DCIT, CIRCLE-2, MUZAFFARPUR

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

Bench: Sri Rajpal Yadav & Dr. Manish Borad

section 36(viia) of the I.T. Act whereas the entire bad debt is an allowable deduction. 11. For that the Ld. CIT(A) has erred in upholding addition of Rs.2,88,460/- on the ground that the same is on account of income tax. 12. For that the disallowance of Rs. 1,40,675/- and additions of Rs.3,68

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

36,520/-. This return was processed under section 143(1) of the Income Tax Act. The ld. Assessing Officer thereafter observed that he has received an information from Investigation Wing that the assessee had obtained bogus accommodation entry in the nature of bogus unsecured loan. According to him, this loan was obtained by the assessee

SAWITA SHAH,PURNIA vs. ITO, WARD-3(1), PURNIA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrasawita Shah, Income Tax Officer, W/O Kamal Kishor Gupta Sudi Ward 3(1), Purnia Tola, Ansari Thakur Tola, Vs Dalmapur, Baisi, Purnia, Bihar - 854315 (Pan: Gnzps0882J) (Appellant) (Respondent)

68 previous year savings can't be treated as unexplained income. On perusal of assessment order it is noticed that the assessing officer has specifically has mentioned that the addition is being made u/s 69A of the Act. Hence the aforesaid contention of the appellant is not found correct. In the light of foregoing discussing and factual aspect

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

PRABHU DAYAL BHARTIYA ,PATNA vs. DC/AC CIRCLE-4, PATNA, PATNA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.372/Pat/2025 Assessment Year: 2013-14 Prabhu Dayal Bhartiya (Huf)….………. …………………....Appellant 701, Shanti Kunj, Chajjubagh, Patna, Bihar- 800001.. [Pan: Aachp7738Q] Vs. Dc/Ac, Circle-4, Patna…....…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 15, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Is Directed By The Assessee Against The Order Dated 16.07.2025 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee, A Hindu Undivided Family (Huf), Filed Its Return Of Income For The Assessment Year 2013– 14 Declaring A Total Income Of ₹6,120/-. The Case Was Reopened Under Section 147 Of The Income-Tax Act, 1961 On The Basis Of Information Received From The Investigation Wing That The Assessee Was A Beneficiary Of Accommodation Entries In The Form Of Long-Term Capital Gains (Ltcg) From The Sale Of Shares Amounting To ₹55,16,804/- Received From M/S. Aayan Commercial Pvt. Ltd. & Its Associate Concerns. It

36,95,540/- under section 10(38) of the Act on account of such alleged bogus LTCG. Accordingly, after obtaining the necessary approval from the competent authority, notice under section 148 of the Act was issued to the assessee. During the reassessment proceedings, the assessee failed to substantiate the genuineness of the share transactions and could not furnish

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

36 PM i.e. within a span of 09 seconds. An investor does not invest for earning losses within a few seconds. Similarly, in the case of Nickel Futures carried out on the same day with Shrestha Beneficiary Trust, despite knowing that the transaction had resulted in loss earlier, the assessee carries out the sale transaction at the price

JITENDRA SINGH,PATNA vs. ACIT, CIRCLE-1, PATNA

In the result, the appeal of the assessee is dismissed

Bench: Shri Manish Borad & Shri Sonjoy Sarma]

section 68 of the Act. Considering the submissions made by the assessee, The AO added a sum of Rs. 6,91,050/- to the income of the assessee and assessed u/s 143(3)/147 of the Income-tax Act, 1961. 3 Jitendra Singh AY 2004-05 4. Dissatisfied with the above order passed by the AO, the assessee preferred

ATLANTIS MEDICARE PRIVATE LIMITED,PATNA vs. DC/AC CIRCLE-1, PATNA

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

36 along with condonation of delay petition\non same day and committed delay which caused delay of 30 days.\n5. That from the perusal of limitation period right from the date of receipt of the order\nof CIT (A) till the date of filing the appeal before the Hon'ble I.T.A.T. Patna entire delay\nis 30 days, whereas the condonations

DCIT, CENTRAL CIRCLE - 2(1), NAGPUR vs. KHARE AND TARKUNDE INFRASTRUCTURE PRIVATE LIMITED, NAGPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh & Shri Khettra Mohan Roydcit, Central Circle-2(1), Khare & Tarkunde Nagpur Vs Infrastructure Pvt. Ltd., 235, Shivaji Complex, Dharmpeth, Nagpur Pan : Aaack 7184 N Department Assessee Assessee By : Shri Sachin V. Luthra, Ca Revenue By : Shri Surjit Kumar Saha, Sr. Dr Date Of Hearing : 25.02.2026 Date Of Pronouncement : 21.04.2026 O R D E R

36,180/-. Case was selected for scrutiny through CASS and statutory notices u/s. 143(2) & 142(1) of the Act were issued and served upon the assessee. In response to the notices issued, assessee made submissions and on perusal of the documents so submitted, Ld. AO noticed that during the assessee sold Transferable Developmental Rights (TDRs

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel

DCIT(EXEMPTION) CIRCLE, PATNA vs. M/S DEO MANGAL MEMORIAL TRUST, PATNA

In the result, these appeals filed by the Revenue are allowed for statistical purposes

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

section 2(15) of the Act. It is seen that there is also a supporting finding that considerable expenses have been claimed under the following heads, which have been debited as under: Expenses Claimed A.Y. 13-14 A.Y. 12-13 Advertisement 3,881,536.00 36,890.00 Consumables 5,387,964.00 3,853,562.00 Power & Fuel

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

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the\nauthority, rather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the\napproval was granted on the same day when the draft assessment\norders were sent, has observed as under

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

SECTION 153D OF THE ACT\nCANNOT BE MERELY A RITUALISTIC FORMALITY OR RUBBER STAMPING BY THE\nAUTHORITY, RATHER IT MUST REFLECT AN APPROPRIATE APPLICATION OF MIND.\n16. IN THE PRESENT CASE, THE ITAT, WHILE SPECIFICALLY NOTING THAT THE\nAPPROVAL WAS GRANTED ON THE SAME DAY WHEN THE DRAFT ASSESSMENT\nORDERS WERE SENT, HAS OBSERVED AS UNDER

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

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the\nauthority, rather it must reflect an appropriate application of mind.\n16. In the present case, the ITAT, while specifically noting that the\napproval was granted on the same day when the draft assessment\norders were sent, has observed as under

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

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

Section 153D of the Act\ncannot be merely a ritualistic formality or rubber stamping by the\nauthority, rather it must reflect an appropriate application of mind.\n16.\nIn the present case, the ITAT, while specifically noting that the\napproval was granted on the same day when the draft assessment\norders were sent, has observed as under

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

Section 153D of the Act cannot be merely a ritualistic formality or rubber stamping by the authority, rather it must reflect an appropriate application of mind. 16. In the present case, the ITAT, while specifically noting that the approval was granted on the same day when the draft assessment orders were sent, has observed as under:- "10. We have