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

2. That the revenue in its appeals have only contested the tax liability for non deduction of TDS as per section 194C/201 (1). The revenue has not disputed the interest liability U/s 201(1A) which is an independent provision and can stand alone/autonomously since the section starts with "Without prejudice to the provisions of sub-section (1)...". As such, revenue

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

2. That the revenue in its appeals have only contested the tax liability for non deduction of TDS as per section 194C/201 (1). The revenue has not disputed the interest liability U/s 201(1A) which is an independent provision and can stand alone/autonomously since the section starts with "Without prejudice to the provisions of sub-section (1)...". As such, revenue

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

29,202. We do not find any infirmity in the well-reasoned order of the CIT(A). Accordingly, this ground of appeal raised by the Revenue is dismissed. 10. Another issue relates to the addition of ₹59,00,000 made by the Assessing Officer under section 68. During the financial year 2014-15, the assessee had received loan amounts aggregating

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

2,29,65,337/-\nTotal value: Rs. 7,75,99,579/-\nShort fall after reconciliation due to non-availability of records in case of Bharat Singh: - Rs. 15,46,00,421\n(23,22,00,000-7,75,99,579).\nProfit & Loss a/c and Balance Sheet of L B Singh, K N Singh and Bharat Singh

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]

29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90,89,176/- (AY 1996-97 to 2005-06) and restricting the same for C.O. No. 07/Ran/2018

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]

29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90,89,176/- (AY 1996-97 to 2005-06) and restricting the same for C.O. No. 07/Ran/2018

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

In the result, all the captioned appeals are hereby dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.299/Ran/2017 Assessment Year: 2009-10 Acit,Central-1, Dhanbad............................................................……Appellant Vs. M/S Bharat Coking Coal Ltd........................................……...…..…..Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] I.T.A No.123/Ran/2018 Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd........................................................…… Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant C.O No.08/Ran/2018 (In Ita No.299/Ran/2017) Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd..................................................... …Cross-Objector Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant Appearances By: Shri Rinku Singh, Cit- Dr., Appeared On Behalf Of The Appellant. Shri M. K. Choudhary With Devesh Poddar, Adv Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 23, 2023 Date Of Pronouncing The Order : July 07, 2023

29,240/- for the AYs 1996-97, 1997-98 & 1999-2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90,89,176/- (AY 1996-97 to 2005-06) and restricting the same for preceding 8 years only by relying

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

In the result, all the captioned appeals are hereby dismissed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.299/Ran/2017 Assessment Year: 2009-10 Acit,Central-1, Dhanbad............................................................……Appellant Vs. M/S Bharat Coking Coal Ltd........................................……...…..…..Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] I.T.A No.123/Ran/2018 Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd........................................................…… Respondent Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant C.O No.08/Ran/2018 (In Ita No.299/Ran/2017) Assessment Year: 2009-10 M/S Bharat Coking Coal Ltd..................................................... …Cross-Objector Koyla Bhawan, Koyla Nagara, Dhanbad—826005 [Pan: Aaacb7934M] Vs. Acit,Central-1, Dhanbad..............................................……...…..….. Appellant Appearances By: Shri Rinku Singh, Cit- Dr., Appeared On Behalf Of The Appellant. Shri M. K. Choudhary With Devesh Poddar, Adv Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 23, 2023 Date Of Pronouncing The Order : July 07, 2023

29,240/- for the AYs 1996-97, 1997-98 & 1999-2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90,89,176/- (AY 1996-97 to 2005-06) and restricting the same for preceding 8 years only by relying

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

2 entities. That merely because AO formed an opinion in favour of the assessee and did not record the same in the order of assessment, will not render the assessment to be erroneous and prejudicial to the interest of revenue. CIT V. Ashish Rajpal (2009) 23 DTR 266/ 320 ITR 674/180 Taxman 623 (Delhi) (High Court) - Where the assessing officer

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

RAJENDRA KUMAR SAHI,RANCHI vs. CIT (APPEAL), DELHI

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.148/Ran/2025 Assessment Year: 2022-23 Rajendra Kumar Sahi………….……………............................……….……Appellant Hulhundu, Hatia, Ranchi, Jharkhand – 834003. [Pan: Agkps0098L] Vs. Cit(Appeal), Jharkhand….....…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 29, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 07.08.2024 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2022–23. 2. Brief Facts Of The Case Are That The Assessee Filed The Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹4,96,520. The Case Was Selected For Scrutiny As The Assessee Had Disclosed Comparatively Low Income Against Receipts On Which Tcs Had Been Deducted. The Assessing Officer (Ao) Noted A Possibility That The Assessee Had Shown Low Income In Order To Reduce Taxable Profits. It Was Also Observed That The Assessee Had Claimed Significantly Higher Tds In The Revised Itr. Therefore, The Ao Intended To Verify The Genuineness Of The Additional Tds Claim & Whether The Corresponding Receipts Had Been Offered To Tax. Accordingly, Notices Under Sections 143(2) & 142(1) Of The Income-Tax Act Were Issued To The Assessee. However, The Assessee Did Not Comply With The Notices. Consequently, The Ao

29, 2025 ORDER Per Sonjoy Sarma, Judicial Member: This appeal by the assessee is directed against the order of the NFAC, Delhi [“CIT(A)”] dated 07.08.2024 under section 250 of the Income-tax Act, 1961 (the “Act”) for the assessment year 2022–23. 2. Brief facts of the case are that the assessee filed the return of income

CCL,RANCHI vs. DCIT CIR-1, RANCHI

29,25,558\n10,09,00,000\n21,99,00,000\n36,08,20,000\n39,21,891\n7,54,00,000\nTotal Rs.\n1,75,11,86,674\n1,10,13,17,344 82,28,00,000 58,07,20,000\nGrand total Disputes Rs.\n13,13,47,37,752\n3. The first issue is with regard to disallowance

DCIT CIR-1, RANCHI vs. CCL, RANCHI

29,25,558\n10,09,00,000\n21,99,00,000\n36,08,20,000\n39,21,891\n7,54,00,000\nTotal Rs.\n1,75,11,86,674\n1,10,13,17,344 82,28,00,000 58,07,20,000\nGrand total Disputes Rs.\n13,13,47,37,752\n3.\nThe first issue is with regard to disallowance

DCIT CIRCLE-1 , RANCHI vs. CCL LTD , RANCHI

29,25,558\n13\nRepair expenses\n14\nStripping Activity Adjustment\n10,09,00,000\n21,99,00,000\n15\nR & D Expenses and Actuary Payment\n36,08,20,000\n16\nExpense u/s 35E\n39,21,891\n7,54,00,000\n17\nInt. u/s 234A/234B\nTotal

DCIT CIR-1,, RANCHI vs. CCL, RANCHI

29,25,558\n13\nRepair expenses\n14\nStripping Activity Adjustment\n15\nR & D Expenses and Actuary Payment\n16\nExpense u/s 35E\n17\nInt. u/s 234A / 234B\n10,09,00,000\n21,99,00,000\n36,08,20,000\n39,21,891\n7,54,00,000\nTotal

DCIT CIR-1 , RANCHI vs. M/S CENTRAL COALFIELDS LTD, RANCHI

29,25,558\n10,09,00,000\n21,99,00,000\n36,08,20,000\n12 Prior period exp. not exceeding Rs. 10 Lacs,\non estimate @ 50%- enhancement\n13 Repair expenses\n14 Stripping Activity Adjustment\n15 R & D Expenses and Actuary Payment\n16 Expense u/s 35E\n17 Int. u/s 234A / 234B\n39,21,891\n7,54,00,000\nTotal

CCL,RANCHI vs. ACIT CIR-1, RANCHI

29,25,558\n10,09,00,000\n21,99,00,000\nRepair expenses\n36,08,20,000\nStripping Activity Adjustment\n39,21,891\n7,54,00,000\nR & D Expenses and Actuary Payment\nExpense u/s 35E\nInt. u/s 234A / 234B\nTotal

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT, CIRCLE-1,, RANCHI

29,25,558\n10,09,00,000\n21,99,00,000\n36,08,20,000\n39,21,891\n7,54,00,000\nTotal Rs.\n1,75,11,86,674\n1,10,13,17,344\n82,28,00,000\n58,07,20,000\nGrand total Disputes Rs.\n13,13,47,37,752\n3. The first issue is with regard to disallowance