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

disallowance of ₹14,38,359 towards diesel allowance, wherein the CIT(A) changed the applicable provision from section 14A to section

NEPAL CHANDRA DEY,RANCHI vs. ASSITANT /DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, RANCHI, RANCHI

In the result, the appeal of the assessee stands dismissed

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. No.63/Ran/2022 Assessment Year: 2018-19 Nepal Chandra Dey.……....…...………………......................……...…..….. Appellant 58, Tatisilwai, Gandhi Nagar, Ranchi – 835103. [Pan: Agrpd0835D] Vs. Acit/Dcit, Circle-1, Ranchi.…..…..………..…….……….…………….. Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 02, 2023 Date Of Pronouncing The Order : May 15, 2023 Order Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 15.06.2022 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’).

disallowance of employees’ contribution to PF/ESI u/s 36(1)(va) read with section 2(24)(x) of the Act. 6. Admittedly, the issue on merits has been set at rest by the recent decision of the Hon’ble Supreme Court in bunch of appeals with the lead case in ‘Checkmate Services Pvt. Ltd vs. CIT’ in Civil Appeal No.2833

TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

Section 35(1)(i). It was a submission that the said R&D led to modifications so as to meet the local emission requirements and as per the agreement the said modifications also belonged to the AE being Cummins Incorporated. 14 Tata Cummins Vs DCIT 4. We have considered the rival submissions. A specific query was raised

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

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 of of its employees like canteen, hostels, etc. business expenditure Commissioner disallowed same on ground that said expenditures had not been properly explained and that assessee

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

disallowance made by the AO out of the freight & cartage expenses on the ground Asse ssmen t Year: 2 013 -20 14 that provisions of section

MUSKAN HOSPITAL &RSEARVH CENTRE ,BOKARO vs. DCIT CIRCLE-3 , BOKARO

In the result, appeal of the assessee is partly allowed

Bench: Shri N.S Sainiassessment Year : 2014-15

disallowed under section 43B or under section 36(1)(va) - Whether SLP against said impugned order was to be dismissed - Held, yes [Para 2] [In favour of assessee]” 8. Respectfully following the decision of Hon’ble Supreme Court in the case of Rajasthan State Beverages Corporation Ltd. (supra), I set aside the orders of lower authorities and delete the addition

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

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 Ltd Vs PCIT Sambalpur in ITA No. 34/CTK/2021 dated 30/05/2022, wherein it was held as under

DCIT CIRCLE-1, DHANBAD vs. BHARAT COKING COAL LTD.,, DHANBAD

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance of under loading charges of Rs. 547.68 lakhs" In the aforesaid judgment the Hon'ble ITAT has cited the judgment of Hon'ble ITAT in ITA No. 289 and 290/Nag/2006 order dated 30.06.2009 for AY 2002-03 and 2003-04. While allowing the appeal of the appellant on the issue of under loading charges, in para

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

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance of under loading charges of Rs. 547.68 lakhs" In the aforesaid judgment the Hon'ble ITAT has cited the judgment of Hon'ble ITAT in ITA No. 289 and 290/Nag/2006 order dated 30.06.2009 for AY 2002-03 and 2003-04. While allowing the appeal of the appellant on the issue of under loading charges, in para

SHRI NAVNEET MODI,RANCHI vs. DCIT,CIRCLE-2, RANCHI

In the result, both appeals of the assessee are allowed

Bench: Shri C.M.Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.106/Ran/2019 & आयकर अऩीऱ सं./Ita No.53/Ran/2019 (नििाारण वषा / Assessment Year :2015-2016 & 2013-2014) Shri Navneet Modi, Vs. Dcit, Circle-2, Ranchi Modi House, Kanke Dam Side Road, Kanke, Ranchi स्थायी ऱेखा सं./ Pan No. : Actpm 1511 F (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri Inderjeet Singh, Cit(Dr)

14 (SC), the Hon'ble Court held that ITA No.2620/Kol/2013 A.Y. 2010-11 ITO Wd-12(1), Kol. vs. M/s Standard Leather Pvt. Ltd. Page 15 cessation of liability for the purpose of section 41(1) means irrevocable cessation so that there is no possibility of the liability being revived in future. If there is such a possibility, then

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 40(a)(ai) of the I.T.Act,1961 same is disallowable expenditure. Further as the details & ledger furnished by the assessee under the head Architect Drawing & MAP Approval are contradictory to each other, 10% of Rs.7,11,280/- (12,50,562 - 2011282 - 3,38,000) is disallowed & to total income of the assessee. Thus total of expenditure disallowed under this

KAMESHWAR ALLOYS AND STEELS PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 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 05.02.2024 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 Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

section 68 of the Act as unexplained cash credit and also disallowed ₹14,182 towards penal expenses. 3. Aggrieved the order

PADAM KUMAE JAIN,RANCHI vs. CIT, CENTRAL, PATNA

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

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./Ita No.289/Ran/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Padam Kumar Jain Vs. Cit, Central, Cr Building, Beer Chand Patel Marg, Patna – 800001. Ratanlalsurajmal Compound, Main Road, Ranchi – 834001, Jharkhand "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abrpj 0001 E (Assessee) .. (Revenue)

Section 14A disallowance Rs. 1,06,955/- (iv).Expenses under different heads Rs. 6,05,900/- (v). Disallowance of Donation Rs. 2,00,000/-. It may be noted that assessee submitted details of first two expenses but assessing officer did not bring on record. 14

M/S NEW PUNJAB MOTOR TRANSPORT ,JAMSHEDPUR vs. ITO WARD-1(2), JAMSHEDPUR

In the result, appeal of the assesse is partly allowed for

Bench: Shri N.S Sainiassessment Year : 2012-13

disallowance was warranted under section 40(a)(ia) of the Act. 13. Ld D.R. supported the orders of lower authorities. 14

ST PATRICKS EDUCATIONAL SOCIETY,GUMLA vs. INCOME TAX OFFICER W3(1), RANCHI

In the result, appeal of the assessee stands allowed

Bench: Shri George Mathan(Through Hybrid Mode) आयकर अपील सं./Ita No.70/Ran/2025 (निर्धारण वर्ा / Assessment Year :2018-2019) St Patricks Educational Vs. Ito, Ward-3(1), Ranchi Society, Sisai Road, Gumla, Jharkhand-835207 स्थायी लेखा सं./Pan No. : Aakas 7872 B (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) ..

disallowed the claim of income not chargeable to tax u/s. 10 was denied. As the dispute is relates to the provision of section 10(23C)(iiiad) it would be relevant to go through the provision of the Act which reads as under: (23C) any income received by any person on behalf of— (i) the Prime Minister's National Relief Fund

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

14 and 2014-15, though disallowed in these two years, the department has allowed the same in subsequent years starting from the A.Y. 2015-16 onwards. 9. It was further submitted by the appellant that the appellant is entitled to claim depreciation on the road under Section

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

14 and 2014-15, though disallowed in these two years, the department has allowed the same in subsequent years starting from the A.Y. 2015-16 onwards. 9. It was further submitted by the appellant that the appellant is entitled to claim depreciation on the road under Section

AADHAR RICE MILL PVT. LTD.,,RANCHI vs. ITO,WARD-1(1), RANCHI

In the result, both appeals of the assessee are allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.294/Ran/2018 & आयकर अऩीऱ सं./Ita No.201/Ran/2019 (नििाारण वषा / Assessment Year :2013-2014 & 2014-2015) M/S Aadhar Rice Mills Pvt. Ltd., Vs. Ito, Ward-1(1), Ranchi C/O Sri Vinay Kumar Jalan, M/S O.P.Jalan & Associates Consultants Llp, 48 Cart Sarai Road, Upper Bazaar, Ranchi, Jharkhand, Pin-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aahca 6463 B (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Vinay Kumar Jalan, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 23/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R The Assessee Has Filed Above Two Appeals Out Of Which Ita No.294/Ran/2018 Has Been Filed Against The Order Of Commissioner Of Income Tax (Appeals), Ranchi, Dated 09.11.2017, Passed In First Appeal No.Cit(A), Ranchi/10058/2016-17 For The Assessment Year 2013-2014, Arising Out Of Order Passed By The Assessing Officer U/S.143(3) Of The Act, Dated 30.03.2016, Whereas Ita No.201/Ran/2019 Has Been Filed By The Assessee For The Assessment Year 2014-2015 Against The Order Passed By The Pr.Cit, Ranchi, Dated 31.03.2019 U/S.263 Of The Act.

Section 263 of the Act. 11. Secondly, from the observations recorded by Their Lodships in the judgment of Hon‟ble Madras High Court in the case of M/s Muthuramalingam Modern Rice Mill (supra) from paras 14 to 20, I observe that the Hon‟ble High Court has clearly held that there is no reason to hold that the activity