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

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

32,000/- under Rule\n8D(2)(iii) of the Rules.\n8. Ld. CIT(A) in the appellate proceedings recorded the finding that\nassessee's own interest free funds were sufficient to cover\ninvestment made in the securities. Ld. CIT(A) noted that the equity\nfund of the assessee was Rs. 4,657 Cr whereas average\ninvestments were only

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

32,000/- under Rule\n8D(2)(iii) of the Rules.\n8. Ld. CIT(A) in the appellate proceedings recorded the finding that\nassessee's own interest free funds were sufficient to cover\ninvestment made in the securities. Ld. CIT(A) noted that the equity\nfund of the assessee was Rs. 4,657 Cr whereas average\ninvestments were only

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

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 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

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

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

32,931.00 1,19,93,553.00 2013-14 9,54,37,653.00 7,55,55,870.00 1,98,81,783.00 2014-15 7,89,22,334.00 5,13,02,422.00 2

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

32,931.00 1,19,93,553.00 2013-14 9,54,37,653.00 7,55,55,870.00 1,98,81,783.00 2014-15 7,89,22,334.00 5,13,02,422.00 2

SHAH BROTHERS,CHAIBASA vs. ACIT CENTRAL CIRCLE-1, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayshah Brothers, A.C.I.T., Thana Lane, Chaibasa-833201 Central Circle-1, Vs. (Jharkhand) Ranchi. Pan No. Aazfs 7498 F Appellant/ Assessee Respondent/ Revenue

2. Shri R.R. Mittal, ld. A.R. is represented on behalf of the assessee and Shri Khub Chand Pandya, ld. Sr.DR is represented on behalf of the revenue. 3. It was submitted by the ld. AR that the assessee is doing work in mining, the assessee had sub-contracted part of its work to Rajshila Nirman Pvt. Ltd.. The said

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

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RANCHI, RANCHI vs. SHRI VIJAY PRASAD, JAMSHEDPUR

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

Bench: Dr Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2012-13 Acit, Central Circle-1, Ranchi Shri Vijay Prasad Flat No. 202, Madhusudan Sir Vs Krishanapuri, Dimna Road Mango, Jamshedpur-831012. Pan: Ailpp 0228 L (Appellant) (Respondent) C.O. No.19/Ran/2021 (Arising Out Of Ita No. 35/Ran/2021) Assessment Year: 2012-13 Shri Vijay Prasad Acit, Central Circle-1, Ranchi Flat No. 202, Madhusudan Sir Vs Krishanapuri, Dimna Road Mango, Jamshedpur-831012. Pan: Ailpp 0228 L (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Pranob Kumar Koley, Sr. Dr Date Of Hearing : 29.11.2023 Date Of Pronouncement : 11.12.2023 O R D E R Per Sonjoy Sarma: Jm This Appeal Is Preferred By The Revenue Against The Order Of Ld. Cit(A)-3, Patna Dated 09.03.2021 Against Same Impugned Order A Cross-Objection Also Filed By The Assessee Being C.O. No. 19/Ran/2021. 2. Brief Facts Of The Case Are The Assessee Filed Its Return Of Income For The A.Y. 2012-13 On 11.09.2012 Showing Total Income Of Rs. 14,32,834/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass & The Assessment In The Case Of Assessee Was Completed U/S 143(3) Of The Act On 28.03.2014 Determining Total Income Of Rs.

32,834/-. The case of the assessee was selected for scrutiny under CASS and the assessment in the case of assessee was completed u/s 143(3) of the Act on 28.03.2014 determining total income of Rs. 2 ITA No.35/RAN/2021 AND C.O. No. 19/RAN/2021 Shri Vijay Prasad A.Y. 2012-13 15,43,400/-. Subsequently, the case of the assessee by virtue

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

In the result, the appeal of the assessee is allowed

32 of this submission for your kind reference.\n1.3.5 That the assessing officer erred in passing order under section\n144 of the Act after considering the reply filed by the assessee in\nresponse to notice issued under section 142(1) by the assessing\nofficer which is not in accordance with the accepted and well\nestablished norms of assessment and therefore

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

TDS claim and whether the corresponding receipts had been offered to tax. Accordingly, notices under sections 143(2) and 142(1) of the Income-tax Act were issued to the assessee. However, the assessee did not comply with the notices. Consequently, the AO I.T.A. No.148/Ran/2025 Rajendra Kumar Sahi completed the assessment ex parte and determined the total income at ₹32

DINESH AGARWAL HUF,PATNA vs. ITO, WARD-1(2), RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

32,658/- for non deduction of TDS is fit to be deleted since TDS as required was rightly deducted and paid by the assessee. The reasons for non deduction was not looked into by the Ld AG and as such, the addition made U/s 40(a)(ia) is fit to be deleted. 5. For that any other grounds in detail

DINESH AGARWAL HUF,PATNA vs. DCIT/ACIT, CIRCLE-1, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

32,658/- for non deduction of TDS is fit to be deleted since TDS as required was rightly deducted and paid by the assessee. The reasons for non deduction was not looked into by the Ld AG and as such, the addition made U/s 40(a)(ia) is fit to be deleted. 5. For that any other grounds in detail

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RANCHI, RANCHI vs. CENTRAL COAL FIELDS LIMITED, 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 (A.Y :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 (A.Y :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 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.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 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

32 of 2017 passed in Writ petition No.5424 of 2020 dated 15/04/2025 wherein the Hon’ble Madhya Pradesh High Court has held as follows:- V. 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

CCL,RANCHI vs. ADDITIONAL CIT RG-1 , 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 (A.Y :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 (A.Y :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 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.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 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

32 of 2017 passed in Writ petition No.5424 of 2020 dated 15/04/2025 wherein the Hon’ble Madhya Pradesh High Court has held as follows:- V. 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

DCIT, CIRCLE-1, RANCHI, RANCHI vs. CENTRAL COALFIELD LIMITED, 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 (A.Y :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 (A.Y :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 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.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 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

32 of 2017 passed in Writ petition No.5424 of 2020 dated 15/04/2025 wherein the Hon’ble Madhya Pradesh High Court has held as follows:- V. 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