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 within the meaning of section 273B of the Act. 6. For that the appellant craves leave to add, amend

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

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 under Section 194C of the Act but since it 2 K.M. Memorial Hospital Vs ACIT has failed to deduct the same. The expenditure claimed at ₹ 3,00,000/- has to be disallowed under Section 40(a)(ia) of the Act. 6

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

6. We have considered the rival submissions and examined the record. It is an admitted fact that the sum of ₹1,64,60,100 represents gross sale proceeds, the transactions are duly recorded in books, the AO has not disputed that the corresponding profit was already included in the assessee’s taxable income, all transactions were executed through a registered

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

6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce any documents evidence/proof like bills, vouchers, debit note made

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

6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce any documents evidence/proof like bills, vouchers, debit note made

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

6. Brief facts of the case are that the assessee has filed its return of income on 06.12.2010 declaring total income of Rs.3,18,050/-. The case was taken up for scrutiny assessment and assessment order was passed under section 143(3) on 31.12.2012. The ld. Assessing Officer has determined the total income of the assessee at Rs.3

RISHIRAJ HOMES PRIVATE LIMITED,JAMSHEDPUR vs. ITO(TDS), JAMSHEDPUR

In the result, all the appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.104, 206 & 207/Ran/2019 (नििाारण वषा / Assessment Year :2013-14, 2014-15 & 2015-16) Rishiraj Homes Private Limited Vs. Ito(Tds), Jamshedpur Contractors Area, Bistupur, Jamshedpur, C/O: Ca Jagdish Khandelwal, 402&403, A.J.Tower, Q. Road, Bistupur, Jamshedpur-831001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaccr 7328 H (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By :Shri Jagdish Khandelwal, Ca(Ar) राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 21/05/2019 घोषणा की तारीख/Date Of Pronouncement 21/05/2019 आदेश / O R D E R These Three Appeals Have Been Filed By The Assessee Against The Separate Order Of Commissioner Of Income Tax (Appeals), Jamshedpur, All Dated 05.11.2018 For The Assessment Years 2013-2014, 2014-2015 & 2015-2016, Respectively. 2. The Sole Issue Involved In All The Thee Appeals Of The Assessee Is That The Cit(A) Erred In Confirming The Order Of Ao Levying Late Fee U/S.234E Of The Act For Delay In Filing Quarterly Statement. 3. Brief Facts Of The Case Are That The Assessee Filed Tds Return In Form No.24Q Financial Year 2012-2013, 2013-2014 & 2014-2015 Relating To Assessment Year 2013-2014, 2014-2015 & 2015-2016, Respectively. Thereafter A Demand Was Raised In All The Three Appeals Under 2

Section 200A, the aforesaid view will not permit the Group of SBI and Ors. Deductor to reopen the said question unless he has made payment under protest." 6. In view of the above, respectfully following 'Shri Fatehraj Singhvi and Others' (supra), 'Sibia Healthcare Pvt. Ltd. vs. DCIT (TDS

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

SRI SITA RAM RAI,DHANBAD vs. ITO TDS WARD, DHANBAD

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.13&14/Ran/2022 Assessment Years: 2013-14 & 2014-15 Sri Sita Ram Rai……..….…..…………..…...…......................……...…..….. Appellant 1, New Karmik Nagar, Ism Saraidhella, Dhanbad, Jharkhand - 826004. [Pan: Afipr2324B] Vs. Ito, Tds Ward-Dhanbad………………………….……….…………….. Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 01, 2023 Date Of Pronouncing The Order : April 28, 2023 Order Per Sanjay Garg: Both The Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In Both The Appeals Has Agitated The Levy Of Late Filing Fees U/S 234E Of The Act Along With Interest Thereupon Levied U/S 220(2) Of The Act. Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.13/Ran/2022 For Assessment Year 2013-14 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. The Brief Facts Of The Case Are That The Assessee Deducted Tax At Source (Tds) In Respect Of Certain Payments. As Per The Provisions Of 1

TDS return u/s 200A of the Act, fees, if any, shall be computed in accordance with the provisions of section 234E of the Act. 4. The ld. counsel, in this respect, has relied upon the decision of the Hon’ble Karnataka High Court in the case of “Fatehraj Singhvi vs. Union of India” 73 Taxmann.com 252 order dated 26.08.2016, wherein

SRI SITA RAM RAI,DHANBAD vs. ITO, DHANBAD

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.13&14/Ran/2022 Assessment Years: 2013-14 & 2014-15 Sri Sita Ram Rai……..….…..…………..…...…......................……...…..….. Appellant 1, New Karmik Nagar, Ism Saraidhella, Dhanbad, Jharkhand - 826004. [Pan: Afipr2324B] Vs. Ito, Tds Ward-Dhanbad………………………….……….…………….. Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 01, 2023 Date Of Pronouncing The Order : April 28, 2023 Order Per Sanjay Garg: Both The Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In Both The Appeals Has Agitated The Levy Of Late Filing Fees U/S 234E Of The Act Along With Interest Thereupon Levied U/S 220(2) Of The Act. Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.13/Ran/2022 For Assessment Year 2013-14 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. The Brief Facts Of The Case Are That The Assessee Deducted Tax At Source (Tds) In Respect Of Certain Payments. As Per The Provisions Of 1

TDS return u/s 200A of the Act, fees, if any, shall be computed in accordance with the provisions of section 234E of the Act. 4. The ld. counsel, in this respect, has relied upon the decision of the Hon’ble Karnataka High Court in the case of “Fatehraj Singhvi vs. Union of India” 73 Taxmann.com 252 order dated 26.08.2016, wherein

M/S GOOD HEALTH FOOD PVT., LTD.,,RANCHI vs. ACIT, CENTRALISED PROCESSING CELL-TDS,, GHAZIABAD

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

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

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

M/S GOOD HEALTH FOOD PVT., LTD.,,RANCHI vs. ACIT, CENTRALISED PROCESSING CELL-TDS,, GHAZIABAD

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

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

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

SHREE BALAJI STEEL WORKS,JAMSHEDPUR vs. ACIT,

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

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

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section

M/S GOOD HEALTH FOOD PVT., LTD.,,RANCHI vs. ACIT, CENTRALISED PROCESSING CELL-TDS,, GHAZIABAD

Bench: Shri S.S, Godara

6. The counsel for the assessee has submitted a statement of TDS returns (APB, Pge. 5-9) contending that all the TDS returns statements has been filed are in respect of the period prior to the date 01.06.2015 i.e. the date from which clause (c) to sub Section