SANJAY CHAWLA,CHAIBASA vs. PR. CIT, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaysanjay Chawla, Pr.C.I.T., Sentola, Chaibasa-833201 (Jharkhand) Ranchi. Vs. Pan No. Acmpc 6808 J Appellant/ Assessee Respondent/ Revenue

section 263 has been invoked for the following reasons:- "Perusal of records reveals that no analysis of quantitative details has been done by the Assessing Officer during the course of assessment proceedings. Sanjay Chawla Vs PCIT Even no inquiry was conducted by the Assessing Officer as to why there was a loss at the Gross Profit Level.” 3. That

M/S BHARAT COOKING COAL LIMITED ,DHANBAD vs. ACIT CIRCLE-1 , DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

ACIT CIR-1 , DHANBAD vs. M/S BHARAT COKING COAL LTD, DHANBAD

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

K M MEMORIAL HOSPITAL & RESERCH CENTRE (P) LTD,BOKARO vs. ACIT, CIRCLE-1,, HAZARIBAG

In the result, this ground of appeal of assessee is partly allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS should be restricted to 30% of that amount under Section 40(a)(ia) of the Act. Accordingly, we also hold that the assessee is entitled to pay 30% of the total amount claimed under Section 40(a)(ia) of the Act. The Assessing Officer is accordingly directed to restrict the addition to 30% of ₹ 3.00 lacs which comes

DEVPRABHA CONSTRUCTION PRIVATE LTD.,,DHANBAD vs. PCIT, DHANBAD

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Devprabha Construction Private Ltd., P.C.I.T., Dev Villa, Behind Radha Swamy Arcade, Dhanbad, Vs. Saraidhela, Dhanbad-828127. Aayakar Bhawan, Luby Pan No. Aaecb 2652 A Circular Road, Dhanbad-826001 (Jharkhand) Appellant/ Assessee Respondent/ Revenue

11-12 wherein annexure 9 i.e. note for non deduction of TDS is at Page 13 and that apart from our submissions we have also attached Form 26A in case of Smt Jaya Devi (Annexure 13, copy of which is at Page 14-16 and M/s Dev Multicom Pvt Ltd (Annexure 12 copy of which is at Page

M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JCIT TDS, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS Dhanbad, vide order dated 01/05/2018 (parallel orders for each year) and same being confirmed by CIT(A) NFAC vide order dated 30/01/2024 (parallel orders for each year). 2. That at the very outset we challenge the very initiation of the penalty proceedings vide notice dated 28/02/2018 (parallel notice for each year) to the extent that the same has been

M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JT. CIT, TDS,, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS Dhanbad, vide order dated 01/05/2018 (parallel orders for each year) and same being confirmed by CIT(A) NFAC vide order dated 30/01/2024 (parallel orders for each year). 2. That at the very outset we challenge the very initiation of the penalty proceedings vide notice dated 28/02/2018 (parallel notice for each year) to the extent that the same has been

M/S. BHARAT COKING COAL LIMITED,,DHANBAD vs. JCIT, TDS CIRCLE,, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS Dhanbad, vide order dated 01/05/2018 (parallel orders for each year) and same being confirmed by CIT(A) NFAC vide order dated 30/01/2024 (parallel orders for each year). 2. That at the very outset we challenge the very initiation of the penalty proceedings vide notice dated 28/02/2018 (parallel notice for each year) to the extent that the same has been

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. BENKO TRADERS PRIVATE LIMITED, KOLKATA

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

11. On this issue, the Id. AR submitted that the assessee had received the said loans in the ordinary course of business, duly recorded them in the books of accounts, and had repaid the same during the year itself. The assessee had also deducted TDS on the interest paid under section 194A of the Act and deposited

ACIT, EXEMPTION CIRCLE, RANCHI vs. M/S. R.V.S. EDUCATIONAL TRUST, JAMSHEDPUR

In the result, appeal of the revenue is dismissed

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am (Through : Hybrid Mode) आयकरअपीलसं./Ita No.24/Ran/2020 (Ǔ""ȡ[""""[/ A.Y. :2016-2017) Acit, Exemption Circle, Ranchi Vs. M/S Rvs Educational Trust, C/O Binda Apartments (India) Private Limited, Siroman Nagar, Dimna Road, Mango, Jamshedpur-831012 ̾Ĉĭēıĕĸù Ĭĝń/Pan No. : Aaatr4456M (\ "Ȣ"ȡ"ȸ/Appellant) (Ĥ×""ȸ/ Respondent) ..

11 of 2012 in the case of the commissionerof income tax Bhubaneswar Vs M/s 5 Silicon institute of technology, Bhubaneswar copy attached marked annex-7. (iii) Disallowance of Advertising Expenditure of Rs.69,66,832 (a) That during the year assesse trust has claimed as application of income under the head advertisement expenses for different units which are as under R.V.S

SHRI VINSHNU KUMAR JALAN,RANCHI vs. ACIT CIR-3, RANCHI

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

Bench: Shri N.S Saini & Pavan Kumar Gadaleassessment Year: 2013-2014

section 194(6) appellant was not liable to make deduction of TDS on the expenses incurred for transportation if the transporter provides the PAN No. The PAN number was provided and was mentioned in the submissions filed before the CIT(A). As such no disallowance is called for and should be deleted.” 3. The brief facts of the case

CCL,RANCHI vs. DCIT CIR01 , RANCHI

In the result, appeal of the assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos. 164,165,166,167,168,169,170&266/Ran/2017 (Α.Υ:2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita Nos.32/Ran/2018 (Ay: 2014-2015) आयकर अपील सं./Ita Nos.190 & 191/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.119, 120, 74/Ran/2024 (Ay: 2018-19, 2019-20 & 2020-21) M/S Central Coalfields Limited, Vs. Addl.Cit, Range-1, Ranchi Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R & आयकर अपील सं./Ita Nos. 172, 173, 174, 175, 176,177,178 & 235/Ran/2017 (Α.Υ:2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita No.37/Ran/2018 (Ay: 2014-2015) आयकर अपील सं./Ita Nos.174 & 175/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.47, 203, 204, 128/Ran/2024 (Ay: 2017-2018, 2018-19, 2019-20 & 2020-21) Addl.Cit, Range-1, Ranchi Vs. M/S Central Coalfields Limited, Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 (अपीलार्थी /Appellant) स्थायी लेखा सं./Pan No. : Aaacc 7476 R (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.Κ.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 05/01/2026 घोषणा की तारीख/Date Of Pronouncement : 05/01/2026 Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017, 30.01.2019, 21.12.2023, 19.02.2024, 20.02.2024 & 30.01.2024 For The

Section 37(1) of the Income-tax Act, 1961 - Business expenditure Allowability of (Welfare expenses of employees) - Assessee- company was engaged in business of coal mining It claimed expenses incurred towards welfare of of its employees like canteen, hostels, etc. business expenditure Commissioner disallowed same on ground that said expenditures had not been properly explained and that assessee

OM PRAAKSH SINGH,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, appeal filed by the assessee is allowed

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Om Prakash Singh Vs. Dcit, Circle-1, Ranchi Sankalp, East Jail Road, Ranchi- 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agkps0300D (अपीलाथ" /Appellant) .. (""थ" / Respondent)

TDS on various items. It appears that no tax has been deducted at source on such payout. As suchit should have been disallowed u/s 40(a)(ia) of the IT Act 1961, which was not done. f. The assessee has not paid sum of Rs. 24,52,623/- on a/c of Central Excise (1994-96) and Rs. 2

SHRIRAM MARKETING SERVICES,GIRIDIH vs. PCIT, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 263 of the Act dated 26/12/2022, set aside the order of Assessing Officer dated 24/09/2021 on the ground that the Assessing Officer did not make any enquiry or investigation to ascertain the nature, source and genuineness of ₹ 2,68,72,976/- and directed the Assessing Officer to make a fresh assessment on the issues discussed above because

M/S COMPREHENSIVE NEOMARKETING SYSTEM PVT. LTD.,,RANCHI vs. ACIT, CENTRALISED PROCESSING CELL-TDS,, GHAZIABAD

Bench: Shri S.S, Godara

TDS UP Page 6 11. In the above view, respectfully following Shri Fatehraj Singhvi and Ors (Supra), Sibia Healthcare Pvt. Ltd. Vs. DCIT (Supra), 'Shri Kaur Oland Jain vs. DCIT', (Supra), and our own finding in the case of Sudershan Goyal (Supra), we accept the grievance of the assessees as genuine. Accordingly, the orders of the CIT(A) are reversed

M/S COMPREHENSIVE NEOMARKETING SYSTEM PVT.,LTD.,,RANCHI vs. ए. सी. आई. टी. सेंट्रलाइज्ड प्रोसेसिंग सेल-टी. डी. एस. , गाजिआबाद

Bench: Shri S.S, Godara

TDS UP Page 6 11. In the above view, respectfully following Shri Fatehraj Singhvi and Ors (Supra), Sibia Healthcare Pvt. Ltd. Vs. DCIT (Supra), 'Shri Kaur Oland Jain vs. DCIT', (Supra), and our own finding in the case of Sudershan Goyal (Supra), we accept the grievance of the assessees as genuine. Accordingly, the orders of the CIT(A) are reversed

C.N.AUTOMOBILES,,RANCHI vs. ACIT,CENTRALISED PROCESSING CELL-TDS, GHAZIABAD

Bench: Shri S.S, Godara

TDS UP Page 6 11. In the above view, respectfully following Shri Fatehraj Singhvi and Ors (Supra), Sibia Healthcare Pvt. Ltd. Vs. DCIT (Supra), 'Shri Kaur Oland Jain vs. DCIT', (Supra), and our own finding in the case of Sudershan Goyal (Supra), we accept the grievance of the assessees as genuine. Accordingly, the orders of the CIT(A) are reversed

SHREE BALAJI STEEL WORKS,JAMSHEDPUR vs. ACIT,

Bench: Shri S.S, Godara

TDS UP Page 6 11. In the above view, respectfully following Shri Fatehraj Singhvi and Ors (Supra), Sibia Healthcare Pvt. Ltd. Vs. DCIT (Supra), 'Shri Kaur Oland Jain vs. DCIT', (Supra), and our own finding in the case of Sudershan Goyal (Supra), we accept the grievance of the assessees as genuine. Accordingly, the orders of the CIT(A) are reversed