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

section 194A for deduction of TDS on interest was not applicable in the facts of the case of the assessee since only a notional/hypothetical entry of aforesaid amount of interest was made. The company was continuously running in loss and was under BIFR for declaration of sick company. M/s OIL, parent company of the appellant, has converted amount due from

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS under this Section, since the payment made to the truck owners in each case is below ₹ 20,000/-, the charging of interest under Section 201(1)/(1A) of the Act has no basis. Accordingly, we uphold the order passed by the ld. CIT(A). In the result, the grounds of appeal raised by the revenue are dismissed

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

TDS under this Section, since the payment made to the truck owners in each case is below ₹ 20,000/-, the charging of interest under Section 201(1)/(1A) of the Act has no basis. Accordingly, we uphold the order passed by the ld. CIT(A). In the result, the grounds of appeal raised by the revenue are dismissed

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

M/S P.K.UPADHYAY vs. ITO WARD-3(5), PALAMAU

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

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

section 194C of the Income Tax Act and, therefore, he disallowed both the items. 11. On due consideration of the facts and circumstances, we are of the view that the Revenue Authorities are not justified in making the above disallowance because on purchase of material, no TDS was required to be deducted by the assessee. Similarly it was submitted

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) ..

12 of the said Act. (ii) Disallowance of Capital Expenditure of Rs.4,39,31,322/- (a) That the assesse trust has made capital expenditure for different units during the year which are as under:- R.V.S. College of Engineering & Technology Rs.2,48,23,302/- R.V.S. International School Rs.1,15,70,373/- R.V.S. Academy Rs. 75,37,646/- Total Rs.4

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

TDS on the interest paid under section 194A of the Act and deposited it in the government account. Complete details. regarding the lenders including confirmations, PAN, audited financial statements, ITR acknowledgments, and bank statements reflecting the loan transactions were furnished before the Ld. AO as well as CIT(A). It was therefore argued that the identity and creditworthiness

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

TDS & TCS provisions. 7. That as stated above, it is not a case where no enquiry or no application of mind has been done by the Ld AO. Apparently what can be opined is only that the Ld PCTT was not fully convinced with the enquiry and verification done by the Ld AO and as such, the powers vested

BADRINATH SALES PRIVATE LIMITED,ADITYAPUR, WEST SINGHBHUM vs. DCIT/ACIT CIRCLE 1 JSR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

12. When, once opening stock is accepted in\nsubsequent year, closing stock of earlier year cannot be disturbed. The\nld. AR submitted his written submissions in the following manner:\n“Issuance of notice beyond the time barring period\n1.1 For ground 1,2 & 3: The Ld. assessing officer has erred\nissuing notice under section 148 beyond the time barring date

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

Section 263 of the Act and set aside the order of Assessing Officer and directed him to make a fresh assessment considering the findings on the issues discussed on each issue and the conclusions drawn. 5. Aggrieved by the order of ld. PCIT, this appeal by the assessee, has been preferred before us. During the appellate proceedings before

JAMSHEDPUR UTILITIES AND SERVICES COMPANY LTD,JSR vs. ACIT CIR-2, JSR

In the result, the appeal of the assessee are partly allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

JUSCO LTD ,JSR vs. DCIT CIR-2 , JSR

In the result, the appeal of the assessee are partly allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

ACIT CIR-2(1), JSR vs. JUSCO LTD , JSR

In the result, the appeal of the assessee are partly allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

ACIT CIR-2(1), JSR vs. JUSCO LTD , JSR

In the result, the appeal of the assessee are partly allowed and the appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

ANWESH KUMAR CHAKRABORTY,KOLKATA vs. ASSESSING OFFICER, JAMSHEDPUR

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes only

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Anwesh Kumar Chakraborty, Assessing Officer, Flat No. 04, Ashabori Apartment, 11/1 Jamshedpur. Vs. Kolupara Lane, Dhakuria, Kolkata-700031 (West Bengal) Pan No. Aiqpc 6936 M Appellant/ Assessee Respondent/ Revenue

Sections 148 to 153, assessee or reassess such income. But in this case, there has been no income which has escaped assessment, the assessing officer in regard to deductions claimed by assessee wanted documentary evidences for the same. 2. The learned CIT(A) is not justified by upholding the AO's order of addition

ACIT,CIRCLE-2(1), HAZARIBAG vs. SANJAY KUMAR UPADHYAY, HAZARIBAG

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

Bench: Sri Sanjay Garg & Dr. Manish Borad

12,79,417/- which is higher. It also submitted that ld. AO seems to have made the mistake inadvertently by taking the figure of the payment received from Executive Engineer, REO Works Division, Hazaribag during the year at Rs. 1,98,79,417/- which is not correct. After considering these submissions, ld. CIT(A) deleted the said addition observing

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

12\nPropristor\nPoonam Entp., Prabha Entp., Priya Entp.\nProp:- Sri. Kumbh Nath Singh\nJharia, Dhanbad.\nProfit & Loss A/c for the year ended 31.03.2012\nPARTIATIARS\nAMOUNT\nPARTICULARS\nAMOUNI\nDe Recewel from BCU!\nTo Sagaus & Bonas\n300,000.00\nBy latt. Receved\nTe liavelling & Conveyance Expenses\n205,000,00\nLol alvar Payment\n118.683,997,00\nTo Bank Changes\n12,137.00\nLo Priating & Stationκη