M/S CHHAGANLAL AGARWAL,CHAIBASA vs. ITO,WARD-3(4), CHAIBASA

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.319/Ran/2018 (नििाारण वषा / Assessment Year :2010-2011) M/S Chhaganlal Agarwal, Vs. Ito Ward-3(4), Chaibasa Bari Bazar, Chaibasa-833201 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaffc 6053 J (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

147 after four years by misinterpretation of provision of income tax act is unjustified and illegal. Ld. AO initiated proceeding based on provision in existence upto A.Y. 2009-10. Ld. CIT(A) went out of way and acted illegally by confirming action of Ld. AO. 2. For that the partnership deed of the appellant firm clearly provided that the mode

M/S. AMAN ENTERPRISES,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Aman Enterprises, D.C.I.T., 22, Park Street, Near Doranda College, Circle-1, Vs. Ranchi-834002 (Jharkhand) Ranchi. Pan No. Aaifa 9921 A Appellant/ Assessee Respondent/ Revenue

Section 147 on 26/11/2018. It was a submission that the reasons recorded are at pages 3 and 4 of the paper book which reads as follows: M/s Aman Enterprises Vs DCIT During the course of scrutiny of income tax records of M/s Aman Enterprises for the A.Y. 2011-12, it has been observed that the assessee has debited

KUMAR PRATIK,KOLKATA vs. INCOME TAX OFFICER, SAHIBGANJ

In the result, this appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Kumar Pratik, I.T.O., Tower C2, Flat 1402, Eden City, Sahibganj. Vs. Mahestala, Kolkata-700137. Pan No. Buapp 7990 K Appellant/ Assessee Respondent/ Revenue

Disallowance under Section 69C of the Income Tax Act. (Addition Rs. 3,08,005/- towards stamp duty and registration charges of Flat. This amount was received from sister, Kumari Sonali for payment of stamp duty and registration. She is my sister and received the amount as gift which is not taxable as received from relative. Kumari Sonali, Doner

M/S CENTRAL COALFIELDS LTD..,RANCHI vs. PRINCIPLE COMMISSIONER OF INCOME TAX, , RANCHI

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

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

147 read with section 143(3) of the Income Tax Act. 3. The ld. Counsel for the assessee, at the very outset, submitted that basic grievance of the ld. Commissioner in taking cognizance under section 263 is that the ld. Assessing Officer failed to disallow

ACIT, CENTRALC CIRCLE-1, RANCHI, RANCHI vs. IMPERIAL AUTOMOBILES PRIVATE LIMITED, KOLKATA

In the result, appeal of the revenue stands dismissed

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

disallowed and added to the income of the assessee. Add: Rs.,7,73,726/- 6. As discussed above, the total income of the assessee is recomputed as under: Returned loss : Rs.47,70,928/- Add: as discussed in para 5 : Rs.7,73,727/- --------------------------------- Taxable total income: Rs.39,97,202/- `Loss round u/s.288A : Rs.39,97,210/- Assessed fu/s.143(3) at a total

GOLDEN GOENKA COMMERCE PVT. LTD.,,KOLKATA vs. ACIT CIRCLE-2(1),, JAMSHEDPUR

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

147 of the Act on the ground that the assessee had raised share capital of ₹4,73,00,000 by issuing 4,73,000 equity shares of ₹10 each at a premium of ₹90 per share, which according to the AO was not satisfactorily explained. Notice under section 148 was issued and in compliance the assessee filed return of income

JAISWAL STEEL INDUSTRIES PRIVATE LIMITED,JAMSHEDPUR vs. ITO WARD 2(1), JAMSHEDPUR

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.284/Ran/2024 Assessment Year: 2016-17 Jaiswal Steel Industries Pvt. Ltd. ….…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831006. [Pan: Aabcj4471C] Vs. Ito, Ward-2(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 02.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

147 read with section 143(3) of the Act. While completing the reassessment, the Assessing Officer determined the total income of the assessee at ₹46,66,974 after adjusting carry forward business loss of ₹1,46,68,519. Further, additions aggregating to ₹1,93,35,493 were made I.T.A. No.284/Ran/2024 Jaiswal Steel Industries Pvt. Ltd. on account of unexplained money

INDICO MOTORS PRIVATE LTD.,JAMSHEDPUR vs. DCIT CIRCLE-1, JAMSHEDPUR

In the result, appeal filed by the assessee is allowed

Bench: Shri N.S Saini & Pavan Kumar Gadaleassessment Year: 2006-2007

disallowed by the Assessing Officer and added back to the income of the assessee.” 4. On the above stated facts, the submission of ld A.R is that the reopening of assessment was made on the basis of change of opinion on the very same set of facts and as no new material came to the knowledge of the Assessing Officer

M/S ALAM HOSPITAL & RESEARCH CENTRE PVT LTD,RANCHI vs. DCIT CIR-2, RANCHI

In the result, grounds of appeal raised by the assessee are allowed for statistic- al purposes only

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

147 dated 31/01/2025 on the same issue of addition where the claim of deduction under Section 80-IB(11C) was disallowed

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

147 puts an embargo upon the powers of the ld. Assessing Officer for reopening of the assessment in the cases where scrutiny assessment was made and four years have expired. This protection is not available in the present case. In the absence of complete details, we are at a loss to record any specific finding on this aspect

HEC LTD,FINANCE &ACCOUNTS,RANCHI vs. ACIT,CIR-1, RANCHI

In the result, all appeals filed by the Revenue are dismissed and all appeals filed by the Assessee are allowed

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

Section 147 of the Income Tax Act, 1961. The reasons recorded were as follows : - "In this case, Assessee Company filed return of income for Assessment Year- 2008-09 on 27.03.2009 through e-filing and has declared total income of Rs. NIL. Further this case was selected for scrutiny and assessment was completed on 30.12.2010 raising total demand

HEC LTD,FINANCE &ACCOUNTS,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, all appeals filed by the Revenue are dismissed and all appeals filed by the Assessee are allowed

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

Section 147 of the Income Tax Act, 1961. The reasons recorded were as follows : - "In this case, Assessee Company filed return of income for Assessment Year- 2008-09 on 27.03.2009 through e-filing and has declared total income of Rs. NIL. Further this case was selected for scrutiny and assessment was completed on 30.12.2010 raising total demand

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

In the result, all appeals filed by the Revenue are dismissed and all appeals filed by the Assessee are allowed

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

Section 147 of the Income Tax Act, 1961. The reasons recorded were as follows : - "In this case, Assessee Company filed return of income for Assessment Year- 2008-09 on 27.03.2009 through e-filing and has declared total income of Rs. NIL. Further this case was selected for scrutiny and assessment was completed on 30.12.2010 raising total demand

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

disallowance u/s 40(a)(ia) has been made by Assessing Officer, in assessment proceedings, the same amount could not be considered as an amount covered by provisions of section 194A so as to raise TDS demand under section 201 or to impose penalty u/s 271C for default of non-deduction of TDS. 3. For that Ld. CIT(A) erred

M/S. BHARAT COKING COAL LIMITED,DHANBAD vs. JCIT TDS, DHANBAD

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance u/s 40(a)(ia) has been made by Assessing Officer, in assessment proceedings, the same amount could not be considered as an amount covered by provisions of section 194A so as to raise TDS demand under section 201 or to impose penalty u/s 271C for default of non-deduction of TDS. 3. For that Ld. CIT(A) erred

M/S. BHARAT COKING COAL LIMITED,,DHANBAD vs. JCIT, TDS CIRCLE,, DHANBAD

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowance u/s 40(a)(ia) has been made by Assessing Officer, in assessment proceedings, the same amount could not be considered as an amount covered by provisions of section 194A so as to raise TDS demand under section 201 or to impose penalty u/s 271C for default of non-deduction of TDS. 3. For that Ld. CIT(A) erred

THE SINGHBHUM DISTRICT CENTRAL COOPERATIVE BANK,CHAIBASA vs. ACIT, NFAC, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.177/Ran/2023 Assessment Year: 2012-13 The Singhbhum District Central Cooperative Bank, Chaibasa...……….……Appellant Represented By Jsbs, Madhubazar, Chaibasa, Jharkhand – 833201. [Pan: Aaajt2036K] Vs. Acit, Nfac, Delhi……….............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Advocate Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Sr. Cit, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2025 Date Of Pronouncing The Order : June 30, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 13.06.2023 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’).

147 of the Act dated 26.12.2018 was passed determining total income of Rs.5,49,82,710/- by disallowing claim of deduction of Rs.5,15,43,257/- u/s 80P of the Act. On examination of assessment record, it was observed that the assessee made provision of Rs.11,46,24,925/- for bad & doubtful debts against non-performing assets

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

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) (Α.Υ :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) निर्धारिती 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 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement 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 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

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

Bench: Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules