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’).

143. (1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of section 142, such return shall be processed in the following manner, namely:— (a) the total income or loss shall be computed after making the following adjustments, namely:— (i) any arithmetical error in the return; [***] (ii) an incorrect claim

SHREE SREE BALANANDA TRUST,DEOGHAR vs. ITO, EXEMPTION WARD,, DHANBAD

In the result, this appeal of assessee is allowed

Bench: Shri Partha Sarathi Chaudhuryshree Sree Balananda Trust, I.T.O., Sri Sri Balananda Ashram, Karinabad, Exemption Ward, Vs. Deoghar, Dist.- Deoghar, Dhanbad. Jharkhand-841112 Pan No. Aabts 0579 H Appellant/ Assessee Respondent/ Revenue

ii) and (iii) of the Act. In the case of S.R.F. Charitable Trust v. Union of India [1992] 193 ITR 95, the Hon'ble Delhi High Court held that as per the provisions of Section 143(1)(a) of the Act the Assessing Officer could allow or disallow

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 Sahayd.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 M/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

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: DCIT Vs M/s CCL & 1 Anr. Sl. Head of addition/disallowance Amount No. (i) Disallowance u/s 14A ₹ 1,64,80,500/- (ii

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 Sahayd.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 M/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

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: DCIT Vs M/s CCL & 1 Anr. Sl. Head of addition/disallowance Amount No. (i) Disallowance u/s 14A ₹ 1,64,80,500/- (ii

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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

disallowed by the Assessing Officer, establishing mens rea in assessee's approach. 4. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs and advocates, still it deliberately filed inaccurate particulars of income. 5. Other grounds, if any, will be raised at the time of hearing." 2. The appeal of the assessee, bearing

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 Sahayd.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 M/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

disallowance of expenses is as under :- Sl. Head Amount Issue involved 1 Lease Rent paid for 133,78,37,000/- Whether revenue the acquisition of expenditure or capital Forest land expenditure. 2 Prior period 8,99,66,000/- Whether ascertained & expenses crystalized during the year. 3 Land & Crop 89,82,07,000/- Whether of enduring Compensation nature i.e. Capital

DCIT,CIRCLE-1RANCHI, 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 Sahayd.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 M/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

disallowance of expenses is as under :- Sl. Head Amount Issue involved 1 Lease Rent paid for 133,78,37,000/- Whether revenue the acquisition of expenditure or capital Forest land expenditure. 2 Prior period 8,99,66,000/- Whether ascertained & expenses crystalized during the year. 3 Land & Crop 89,82,07,000/- Whether of enduring Compensation nature i.e. Capital

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

1. The Ld. CIT(A) had erred in restricting the penalty to its minimum, while the AO was fully justified in imposing penalty @ 150% of tax sought to be evaded. The Assessee has given inaccurate particulars of allowable expenses and the same has been confirmed by the Ld.CIT(A) in his order relating to the Assessment order

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

1. The Ld. CIT(A) had erred in restricting the penalty to its minimum, while the AO was fully justified in imposing penalty @ 150% of tax sought to be evaded. The Assessee has given inaccurate particulars of allowable expenses and the same has been confirmed by the Ld.CIT(A) in his order relating to the Assessment order

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

In the result, appeal of the assessee is allowed

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

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: Sl. Head of addition/disallowance Amount No. (i) Disallowance u/s 14A ₹ 2,12,51,000/- (ii) Prior period expenses ₹ 2,21,98,000/- (iii) Land & Crop Compensation ₹ 2,80,62,000/- (iv) Sports grant and grants

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

1. The Ld. CIT(A) had erred in restricting the penalty to its minimum, while the AO was fully justified in imposing penalty @ 150% of tax sought to be evaded. The Assessee has given inaccurate particulars of allowable expenses and the same has been confirmed by the Ld.CIT(A) in his order relating to the Assessment order

NEERAJ KUMAR SINHA,JAMSHEDPUR vs. ITO WARD-1(1), JAMSHEDPUR

In the result, this appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayneeraj Kumar Sinha, I.T.O., Prop.-M/S Neeraj Engineering, Chota Ward-1(1), Vs. Ghamaria, Saraikela-Kharsawan, Jamshedpur. Jamshedpur-832108 (Jharkhand) Pan No. Bopps 2885 K Appellant/ Assessee Respondent/ Revenue

ii) provides that the adjustment of an incorrect claim can be made if such incorrect claim is apparent from any information in the return. The issue which is being disputed and for which two opinions can be formed relying upon the various decisions of various High Courts, the majority of which are in favour of the appellant including the decision

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\nis dismissed

1. The Ld. CIT(A) had erred in restricting the penalty to its minimum, while the\nAO was fully justified in imposing penalty @ 150% of tax sought to be evaded.\n2. The Assessee has given inaccurate particulars of allowable expenses and the\nsame has been confirmed by the Ld.CIT(A) in his order relating to the\nAssessment order

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

disallowance and estimated the profit arbitrarily @ 8% of the gross receipts. Under these circumstances I tend to agree with the submission of the appellant and therefore by squarely relying on the decisions cited by the appellant (supra), the AO is directed to compute profit @ 8% of Gross receipts after allowing depreciation. In other words the net addition sustained is Rs.26

PREM CHAND SINGH,CHATRA vs. PR.CIT, DHANBAD

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.107/Ran/2024 Assessment Year: 2018-19 Pravin Engineering Pvt. Ltd.......................…...........................……….……Appellant Plot No.6A, Phase-1, Industrial Area, Adityapur, Jharkhand - 832109. [Pan: Aabcp0358E] Vs. Acit, National E-Assessment Centre, New Delhi.……........……...…..…..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 : September 10, 2025 Date Of Pronouncing The Order : September 11, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 28.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] 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 A Company & Filed Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.73,21,980/-. The Case Of The Was Selected For Scrutiny & The Assessing Officer Completed The Assessment U/S 143(3) Of The Act Assessing Total Income Of The Assessee At Rs.84,67,210/-. During The Assessment Proceedings, The Assessing Officer Pointed Out That The Tax Audit Report Has Identified That The Assessee Paid Its Directors A Sum Of Rs.11,36,000/- As Bonus Or Commission Which Was Otherwise Payable As Profits Or Dividend & This Amount Was Covered By Section 36(1)(Ii) Of The Act. The Assessing Officer Disallowed The Claim Of Commission As Claimed By The Assessee.

143(3) of the Act assessing total income of the assessee at Rs.84,67,210/-. During the assessment proceedings, the Assessing Officer pointed out that the tax audit report has identified that the assessee paid its directors a sum of Rs.11,36,000/- as bonus or commission which was otherwise payable as profits or dividend and this amount was covered