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

3) read with section 263 dated 28/03/2025 and no addition was made except some expenditure was disallowed under Section 37 read with section 40A(2b) of the Act on estimate basis being 20% of the expenditure claimed. The Ld. AR, then placed reliance on the decision made by Hon'ble ITAT Cuttack Bench in the case of M/s Ravi Metallics

MISRILALL JAIN & SONS,SINGHBHUM WEST vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result the appeal filed by the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

section 148A(b). In this case of the assessee, the show cause notice and the order U/s 148A(d) only talked about escapement of income to the tune of Rs. 1,32,63,010/- which has already been disclosed by the assessee in the revised return and that the same has I.T.A. No.468/Ran/2025 Misrilall Jain & Sons been accepted. The assessing

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

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

3,06,00,000/- (v) Mines Closure Expenses ₹ 1,05,13,00,000/- (vi) CMPDIL expenses ₹ 51,68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (viii) Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

3,06,00,000/- (v) Mines Closure Expenses ₹ 1,05,13,00,000/- (vi) CMPDIL expenses ₹ 51,68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (viii) Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances were made: M/s CCL Vs DCIT & 1 Anr. Sl. No. Head of addition/disallowance Amount (i) Income from tax free bonds & applicability ₹ 33,45,000/- of Sec. 14A of the I.T. Act. (ii) Depreciation

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

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances were made: M/s CCL Vs DCIT & 1 Anr. Sl. No. Head of addition/disallowance Amount (i) Income from tax free bonds & applicability ₹ 33,45,000/- of Sec. 14A of the I.T. Act. (ii) Depreciation

JHARKHAND ROAD PROJECTS IMPLEMENTATION CO. LTD,RANCHI vs. DCIT CENT. CIRCLE-1, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

3. In response to the above query, the assessee submitted all the details and also produced books of account and were duly examined by the Assessing Officer. The assessee also placed reliance on various decisions in support of its claim of depreciation. The Assessing Officer considered the same but disallowed the depreciation amounting to ₹ 1,62,10,53,316/- claimed

JHARKHAND ROAD PROJECTS IMPLEMENTATION COMPANY LIMITED,RANCHI vs. DCIT,C.C.-1, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

3. In response to the above query, the assessee submitted all the details and also produced books of account and were duly examined by the Assessing Officer. The assessee also placed reliance on various decisions in support of its claim of depreciation. The Assessing Officer considered the same but disallowed the depreciation amounting to ₹ 1,62,10,53,316/- claimed

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

Section\n1\nUnabsorbed depreciation - covereed by ITAT\norder Dt. 31.03.2023 of AY 2008-09 u/s 143(3)\n263/143(3)\n147/143

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

Section\n1\nUnabsorbed depreciation - covereed by ITAT\norder Dt. 31.03.2023 of AY 2008-09 u/s 143(3)\n263/143(3)\n147/143

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

Section\n1\nUnabsorbed depreciation - covereed by ITAT\norder Dt. 31.03.2023 of AY 2008-09 u/s 143(3)\n263/143(3)\n147/143

ACIT.CIRCLE-1 ,, RANCHI vs. MOHINI DEVI CHARITABLE TRUST, VARANASI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

depreciation amounting to Rs.1,32,68,744/-. 3. With the assistance of ld. Representatives, we have gone through the record carefully. A perusal of the record would suggest that the assessee is a Charitable Institution duly registered under section

SHRI KIRTIMAN SINGH,RANCHI vs. DCIT, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Hybrid Hearing) Shri Kirtiman Singh, D.C.I.T., 357/A, Professor Colony, Karam Toli, Circle-2, Vs. Behind Abhilasha Building, Morabadi, Ranchi. Ranchi-834001. Pan No. Awmps 5592 F Appellant/ Assessee Respondent/ Revenue

Section 145(3) of the Act and estimated the income at Rs. 20,09,770/- @ 10% of total turnover. ITA 122/Ran/2016 Shri Kirtiman Singh Vs DCIT 3. Aggrieved by the order of Assessing Officer, the assessee preferred appeal before the ld. CIT(A), who vide the impugned order, restricted the addition to 8% of the total contract receipts. 4. Aggrieved

JOKHIRAM DURGADUTT,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayjokhiram Durgadutt, D.C.I.T., 9, J.D. Corporate, Behind J.D. High Circle-1, Vs. Street, Main Road, Ranchi-834001 Ranchi. (Jharkhand) Pan No. Aabfj 2200 Q Appellant/ Assessee Respondent/ Revenue

section 271 (1)(c)." 4. The contention of the Ld. Commissioner of Income Tax ( Appeal ) that the assessee had claimed an unallowable standard deduction of Rs. 68,36,208/- is fully compensated by way of depreciation being allowed Rs. 2,31,19,350/-. So, the revenue is no way being put at loss or in other wards the assessee

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

In the result, both appeals of revenue and the cross objections of the assessee are dismissed and appeals of assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (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 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 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 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011-

section 32(2) of the Act. Therefore, the ld. CIT(A), Dhanbad erred in allowing the prior period depreciation to the assessee and order passed by the ld. AO needed to be restored. On the other hand, ld. AR submitted that unabsorbed depreciation could be allowed to the assessee to be carried forward 3

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

Section\n300/R/17\nAY 09-10\n302/R/17\nAY 11-12\n1\nUnabsorbed depreciation - covereed by ITAT\norder Dt. 31.03.2023 of AY 2008-09 u/s 143(3

M/S. HIMACHAL CONSTRUCTION CO. PVT. LTD,JAMSHEDPUR vs. ITO, WARD NO.1(5), JAMSHEDPUR

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

Bench: Dr. Manish Borad & Sonjoy Sarma

depreciation. In other words the net addition sustained is Rs.26,34,060/-(Rs.41,43,171 - 15,09,111) as against addition made of Rs.55,24,228/- and the appellant gets a part relief of Rs. 28,90,168/-. Accordingly, this ground is partly allowed.” 6. Now, before us, ld. Counsel for the assessee has referred to the decision of this

ABILITY SERVICES PRIVATE LIMITED,SAKCHI vs. ACIT, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.20/Ran/2024 Assessment Year: 2014-15 Ability Services Pvt. Ltd…….....................…...........................……….……Appellant 232 Kumhar Para, New Baradwari Sakchi, Jharkhand-831001. [Pan: Aacce1395H] Vs. Acit, Circle-1, Jamshedpur.....…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 02, 2025 Date Of Pronouncing The Order : July 09, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 18.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Contract & Transportation & Filed Its Return Of Income For The Assessment Year 2014-15 By Declaring Total Income Of Rs.81,52,900/-. The Case Of The Assessee Was Selected For Scrutiny & Assessment Was Framed On A Total Assessed Income Of Rs.84,49,220/-. Subsequnetly, Proceedings U/S 148 Were Initiated Vide Notice Dated 30.03.2021 & Assessment Was Completed On 20.03.2022 Wherein The Assessing Officer Made Addition Of Excess Depreciation Of Rs.36,64,657/- & Payment Of Epf/Esi Beyond The Due Date But Prior To Filing Of Return Of Rs.5,31,940/-

depreciation of Rs.36,64,657/- and payment of EPF/ESI beyond the due date but prior to filing of return of Rs.5,31,940/- I.T.A. No.20/Ran/2024 Ability Services Pvt. Ltd 4. Dissatisfied with the above order, the assessee preferred an appeal before the ld. CIT(A) against the reassessment order, where the ld. CIT(A) dismissed the appeal of the assessee

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

3. At the outset, both the ld. representatives of the parties have submitted that the issue is squarely covered in favour of the assessee and against the revenue by the decision of the Coordinate bench of the Tribunal in the own case of the assessee for assessment year 2008-09 vide order dated 31.03.2023 passed in ITA No.298/Ran/2017