M/S. CENTRAL COAL FIELDS LTD.,,RANCHI vs. ACIT/DCIT CIRCLE-1, RANCHI

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 (Α.Υ: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 (Α.Υ: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 (अपीलार्थी /Appellant) स्थायी लेखा सं./Pan No. : Aaacc 7476 R (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.Κ.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 Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017, 30.01.2019, 21.12.2023, 19.02.2024, 20.02.2024 & 30.01.2024 For The

10,13,17,344 82,28,00,000 58,07,20,000 Grand total Disputes Rs. 13,13,47,37,752 3. The first issue is with regard to disallowance of Lease Rent/Depreciation Forest Land expenses. It was submitted that the assessee in some years has paid and some years been treated as the amortisation over the period of lease

SURYA REALCON PRIVATE LIMITED,SARAIDHELA, DHANBAD vs. DCIT, AAYAKAR BHAWAN, DHANBAD

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowed under section 801B(10) of the Act only on the ground that the return of income was filed beyond the period stipulated under section 139(l) of the Act in view of the provisions of Section 80AC of the Act as the same is beyond the scope of Section 139(1) of the Act the submission of return within

SURYA REALCON PRIVATE LIMITED,SARAIDHELA, DHANBAD vs. DCIT, AAYAKAR BHAWAN, DHANBAD

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowed under section 801B(10) of the Act only on the ground that the return of income was filed beyond the period stipulated under section 139(l) of the Act in view of the provisions of Section 80AC of the Act as the same is beyond the scope of Section 139(1) of the Act the submission of return within

SHIV PRASAD RAM,BOKARO vs. ASSESSING OFFICER, BOKARO

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Shiv Prasad Ram, I.T.O., Near Petrol Pump, Sector-9/A, Basanti Ward 3(1), Vs. More, Sector-Ix, S.O. Alkusa, Bokaro. Bokaro-827009 (Jharkhand) Pan No. Aqepr 2909 K Appellant/ Assessee Respondent/ Revenue

10(10AA). d) Failure to Substantiate Notices The learned AO did not provide adequate opportunity for the appellant to explain the retirement benefits due to insufficient communication. Multiple notices under Sections 142(1) and 133(6) were not complied with because of disconnection from the employer's accounts division post-retirement. This communication gap should not be the sole reason

ACIT vs. M/S XAVIER INSTITUTE OF SOCIAL SERVICE,

In the result, appeal filed by the revenue is dismissed

Bench: Shri N.S Saini & Pavan Kumar Gadaleassessment Year: 2009-2010

5 IT A No.1 00/R an/2 014 Asse ssmen t Year: 2 009 -20 10 04/1071-73 dated 15.12.2003. The assessee is a trust and exemption under section 10(23C)(vi) of the Act for the F.Y. 2009-10 was granted to the assessee on 8.9.2009 vide Memo No.CCIT/Ran/Tech/10(23C)/13/2008-09/4351-4410. It has also been accepted by both the AO during

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

In the result, appeal of the assessee in ITA No

10,13,17,344 82,28,00,000 58,07,20,000 Grand total Disputes Rs. 13,13,47,37,752 3. The first issue is with regard to disallowance of Lease Rent/Depreciation Forest Land expenses. It was submitted that the assessee in some years has paid and some years been treated as the amortisation over the period of lease

M/S USHA MARTIN LTD,KOLKATA vs. ACIT CIR-3, RANCHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

10,64,429/- being Rs.20,53,221/- had made without considering the fact that the asessee itself has disallowed Rs.,2,27,69,056/-. In the ground, the assessee has prayed for reduction of the disallowance of 5% on the balance amount after reducing the disallowance made by the assessee. It was the submission that consequently, itis a total disallowance

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

ACIT, RANCHI vs. M/S M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

M/S ADITYA BIRLA CHEMICALS INDIA LTD.,PALAMAU vs. ACIT, RANCHI

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

ACIT, RANCHI vs. M/S ADITYA BIRLA CHEMICALS INDIA LTD., PALAMAU

In the result, Assessee`s appeals are allowed and Revenue`s appeals are dismissed and cross objections filed by the assessee are allowed to the extent indicated above

Bench: Shri S.S.Godara, Jm & Dr. A. L. Saini, Am I.T.A Nos. 125 To 127/Ran/2015 Assessment Years: 2008-09 To 2010-11 M/S. Aditya Birla Chemicals India Vs. Acit, Circle – 1, Ltd. (Formerly Known As Bihar Ranchi Caustic & Chemicals Ltd.) Rehla, Palamau – 822124. Pan/Gir No. : Aaacb 7747 A (Appellant) .. (Respondent)

5) of Section 80IA, observed that the word derived from cannot have a wide import and derivation of income must be directly connected with the business in the sense that the income is generated by the business. Thereafter the Assessing officer referred to sub-section (8) of Section 80IA, observed that it was clear that one had to take

ITO WARD-1(40, JSR vs. M/S ANAND VIHAR CONSTRUCTION PVT LTD, JSR

In the result, appeal of the Revenue is dismissed and the cross

Bench: Shri N.S.Saini & Shri Pavan Kumar Gadaleassessment Year : 2014-2015 Ito, Ward-1(4), Jamshedpur Vs M/S Anand Vihar Construction Pvt. Ltd., 12A, Rajendra Nagar, Near Durga Puja Maidan, Sakchi, Jamshedpur- 831001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. & Co No.02/Ran/2018 Assessment Year : 2014-2015 M/S Anand Vihar Construction Vs Ito, Ward-1(4), Pvt. Ltd., Jamshedpur 12A, Rajendra Nagar, Near Durga Puja Maidan, Sakchi, Jamshedpur-831001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. Revenue By Shri A.K.Mohanty,Jcit(Jr. Dr) Assessee By Shri Devesh Poddar, Adv. Date Of Hearing : 27.11.2018 Date Of Pronouncement : 28.11.2018

section 194C does not attract in this case and therefore consequential disallowance u/s 40(a)(ia) is also not attracted. And CO No.02/Ran/2018 Therefore disallowance made for Rs. 2,15,01,768/- is not proper and is hereby deleted. Further the CIT(A) in respect of third ground, has granted relief of Rs.71,128/- out of the total addition

DCIT CIR-1,, RANCHI vs. CCL, 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 (Α.Υ: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 (Α.Υ: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 (अपीलार्थी /Appellant) स्थायी लेखा सं./Pan No. : Aaacc 7476 R (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.Κ.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 Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017, 30.01.2019, 21.12.2023, 19.02.2024, 20.02.2024 & 30.01.2024 For The

Section 14A of the Act was in existence and the some disallowances were called for. It was submitted that the disallowance should be proportionate to the investment made. 33. In rejoinder, Id. AR submitted that the bonds were on account of securitization of the debts. It was the submission that in the earlier years the Id.CIT(A) has held this

DCIT CIR-1, RANCHI vs. M/S JHARKHAND STATE CO-OPERATIVE LAC MARKETING AND PROCUREMENT FEDRATION LTD., RANCHI

In the result, appeal of the Revenue i

Bench: Shri N.S.Saini & Shri Pavan Kumar Gadaleassessment Year : 2011-2012 Dcit, Cirlce-1, Ranchi Vs M/S The Jharkhand State Co-Operative Lac Marketing & Procurement Fed. Ltd. Jhascolampf Building Purulia Road, Bharatpuri, Ranchi-834001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. & Assessment Year : 2012-2013 M/S The Jharkhand State Co- Vs Dcit, Cirlce-3, Ranchi Operative Lac Marketing & Procurement Fed. Ltd. Jhascolampf Building Purulia Road, Bharatpuri, Ranchi-834001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. Revenue By Shri A.K.Mohanty,Jcit(Jr. Dr) Assessee By Shri Nitin Pasari, Adv. Date Of Hearing : 27.11.2018 Date Of Pronouncement : 29.11.2018

10(27) of the Act by the assessee for the A.Y. 2011 -12 is not allowable 3. Brief facts of the case are that the assessee is a Federation of Co-operative Societies registered under the provisions of Jharkhand State Co-operative Societies Act, 1935 and is engaged in the activity of promoting the marketing and procurement

M/S JHARKHAND STATE CO-OPERATIVE LAC MARKETING & PROCUREMENT FED.LTD.,RANCHI vs. DCIT, CIRCLE-3, RANCHI

In the result, appeal of the Revenue i

Bench: Shri N.S.Saini & Shri Pavan Kumar Gadaleassessment Year : 2011-2012 Dcit, Cirlce-1, Ranchi Vs M/S The Jharkhand State Co-Operative Lac Marketing & Procurement Fed. Ltd. Jhascolampf Building Purulia Road, Bharatpuri, Ranchi-834001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. & Assessment Year : 2012-2013 M/S The Jharkhand State Co- Vs Dcit, Cirlce-3, Ranchi Operative Lac Marketing & Procurement Fed. Ltd. Jhascolampf Building Purulia Road, Bharatpuri, Ranchi-834001 Pan No. : Aaacc 7476 R Respondent (Appellant) .. Revenue By Shri A.K.Mohanty,Jcit(Jr. Dr) Assessee By Shri Nitin Pasari, Adv. Date Of Hearing : 27.11.2018 Date Of Pronouncement : 29.11.2018

10(27) of the Act by the assessee for the A.Y. 2011 -12 is not allowable 3. Brief facts of the case are that the assessee is a Federation of Co-operative Societies registered under the provisions of Jharkhand State Co-operative Societies Act, 1935 and is engaged in the activity of promoting the marketing and procurement

M/S MANIKARAN POWER LTD,RANCHI vs. ACIT, CIRCLE-2, RANCHI

In the result, the appeal of the assessee in ITA No

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 01/Ran/2025 (Assessment Year: 2022-23) A.C.I.T., Manikaran Power Limited, Central Circle-2, Manikaran Tower, Kilburn Colony, Vs. Ranchi. P.O. Hinoo, Ranchi-834002 (Jharkhand) J.C.I.T. (In Situ), Pan No. Aaecm 4555 F Ranchi. Revenue/ Appellant Respondent/ Assessee Manikaran Power Limited, A.C.I.T., Manikaran Tower, Kilburn Colony, Central Circle-2, Vs. P.O. Hinoo, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Aaecm 4555 F Revenue/ Appellant Respondent/ Assessee

disallowed under Section 37(1) of the Act. It was a submissions that on appeal, the ld. CIT(A) held that in respect of the issue of bogus purchases, the same could not be considered under Section 68 of the Act and the same was liable to be considered under Section 37(1) of the Act. It was a submission

M/S ANJENEYA ISPAT LTD.,SARAIKELA vs. DEPUTY COMMISSIONE OF INCOME TAX, CIRCELE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.75/Ran/2022 Assessment Year: 2009-10 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand- 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Cit(A)”) Dated 25.09.2017 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2019–20 Declaring A Total Income Of ₹62,64,116. The Case Was Selected For Complete Scrutiny. During The Relevant Previous Year, A Survey Operation Under Section 133A Of The Income-Tax Act, 1961 Was Conducted At The Business Premises Of The Assessee On 16.02.2019. Subsequently, Statutory Notices Under Sections 143(2) & 142(1) Of The Act Were Issued. In Response Thereto, The Assessee Appeared From Time To Time & Furnished Various Details & Documents As Called For. The Same Were Examined & Discussed By The Assessing Officer During The Course Of Assessment Proceedings. During

10(23). Accordingly, the AO disallowed the amount under section 14A of the Act. The AO also observed that tax was not deducted at source on the said payment. The Assessing Officer further made the following additions: 1. Unexplained investment of ₹17,70,410 under section 69, as the assessee failed to produce supporting evidence. I.T.A. No.75/Ran/2022 M/s Anjeneya Ispat