U C I L,JADUGODA vs. ACIT, CIRCLE-3, JAMSHEDPUR

In the result, the appeal of the revenue is dismissed

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleita Nos.384 & 385/Ran/2018 Assessment Year: 2013-14 & 2014-15 M/S. Uranium Corporation Of Acit, Circle -(3), India Ltd. Jamshedpur Vs Jadugoda Mines, Jadugoda, East Singhbhum-832102, Jharkhand. Pan: Aaacu 2207 N (Appellant) (Respondent) Present For: Appellant By : Shri P.K. Barman With Arijit Bhattacherjee, Ar Respondent By : Smt. Rinku Singh, Cit, Dr Date Of Hearing : 03.05.2023 Date Of Pronouncement : 11.05.2023 O R D E R Per Sonjoy Sarma, Jm: The Captioned Appeals Are Filed By The Assessee Are Directed Against The Order Of Ld. Cit(A), Jamshedpur Vide Order Dated 07.10.2016 & 12.09.2017 Respectively For The A.Y. 2013-14 & 2014-15. The Assessee Has Raised Following Grounds Of Appeal For Each Of The Assessment Year Under Consideration: A.Y. 2013-14 “I. For That The Learned Lower Authorities Are Not Justified In Disallowing Rs. 2,23,90,022/- Under The Head Corporate Social Responsibility U/S 37(1) Of The Income-Tax Act, 1961 As The Same Was Altogether In The Past Allowed By The Income Tax Department/Hon’Ble Itat & Consequently The Addition Of Rs. 2,23,90,022/- Is Liable To Be Deleted In To-To.”

disallowed a sum of Rs. 2,23,90,022/- made by the assessee under the head of corporate social responsibility (CSR) and Rs. 1,36,000/- under the head of donation made to the various parties by the assessee. 3. Aggrieved by the above order, assessee preferred an appeal before the ld. CIT(A) wherein the appeal of the assessee

M/S. U C I L ,JADUGODA vs. ACIT, CIRCLE-3, JAMSHEDPUR

In the result, the appeal of the revenue is dismissed

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleita Nos.384 & 385/Ran/2018 Assessment Year: 2013-14 & 2014-15 M/S. Uranium Corporation Of Acit, Circle -(3), India Ltd. Jamshedpur Vs Jadugoda Mines, Jadugoda, East Singhbhum-832102, Jharkhand. Pan: Aaacu 2207 N (Appellant) (Respondent) Present For: Appellant By : Shri P.K. Barman With Arijit Bhattacherjee, Ar Respondent By : Smt. Rinku Singh, Cit, Dr Date Of Hearing : 03.05.2023 Date Of Pronouncement : 11.05.2023 O R D E R Per Sonjoy Sarma, Jm: The Captioned Appeals Are Filed By The Assessee Are Directed Against The Order Of Ld. Cit(A), Jamshedpur Vide Order Dated 07.10.2016 & 12.09.2017 Respectively For The A.Y. 2013-14 & 2014-15. The Assessee Has Raised Following Grounds Of Appeal For Each Of The Assessment Year Under Consideration: A.Y. 2013-14 “I. For That The Learned Lower Authorities Are Not Justified In Disallowing Rs. 2,23,90,022/- Under The Head Corporate Social Responsibility U/S 37(1) Of The Income-Tax Act, 1961 As The Same Was Altogether In The Past Allowed By The Income Tax Department/Hon’Ble Itat & Consequently The Addition Of Rs. 2,23,90,022/- Is Liable To Be Deleted In To-To.”

disallowed a sum of Rs. 2,23,90,022/- made by the assessee under the head of corporate social responsibility (CSR) and Rs. 1,36,000/- under the head of donation made to the various parties by the assessee. 3. Aggrieved by the above order, assessee preferred an appeal before the ld. CIT(A) wherein the appeal of the assessee

ACIT CIR-2(1), JSR vs. JUSCO LTD , JSR

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

JUSCO LTD ,JSR vs. DCIT CIR-2 , JSR

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

JAMSHEDPUR UTILITIES AND SERVICES COMPANY LTD,JSR vs. ACIT CIR-2, JSR

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

ACIT CIR-2(1), JSR vs. JUSCO LTD , JSR

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

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 80IA(4)(iii) of the Act. The AO noted that Form no. 10CCB is mandatory along with return or during the assessment proceedings but the assessee company has not ITA Nos. 8 & 9/Ran/2018 AY: 2013-14 & 2014-15 M/s Jamshedpur Utilities & Services Company Ltd. submitted the Form no. 10CCB. Accordingly the counsel of the assessee was asked to explain

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

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

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

23,53,48,000/- claimed by the assessee but no action was taken upon the assessee by the department on such issue. However, during the course of appellate proceedings, the ld. CIT(A) has issued an enhancement notice to the appellant vide letter dated 26.05.2017 u/s 251(1) read with section 251(1)(2) to show cause that

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

In the result, appeal of the revenue is dismissed and appeal by the assessee is partly allowed as well as cross-objection by the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

23,53,48,000/- claimed by the assessee but no action was taken upon the assessee by the department on such issue. However, during the course of appellate proceedings, the ld. CIT(A) has issued an enhancement notice to the appellant vide letter dated 26.05.2017 u/s 251(1) read with section 251(1)(2) to show cause that

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

M/S PINNACLE CAPITAL SOLUTIONS PRIVATE LIMITED,RANCHI vs. PCIT, RANCHI, CENTRAL REVENUE BUILDING, 5, MAIN ROAD, RANCHI-834004

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Pinnacle Capital Solutions (P) Ltd., P.C.I.T., Virdi Niwas, Jamshedpur, East Ranchi. Vs. Singhbhum, Jharkhand-831001. Pan No. Aaacp 9726 H Appellant/ Assessee Respondent/ Revenue

2,36,88,041/-. As per Section 36(viia)(d) of the Act, the bad debts cannot exceed 5% of the total income computed before making any deduction under ITA 130/Ran/2023 M/s Pinnacle Capital Solutions P ltd. Vs PCIT Section 36(viia)(d) of the Act and Chapter (VIA). Since 5% of Rs. 7,19,23,183/- comes

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

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 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

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

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

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

2 entities. That merely because AO formed an opinion in favour of the assessee and did not record the same in the order of assessment, will not render the assessment to be erroneous and prejudicial to the interest of revenue. CIT V. Ashish Rajpal (2009) 23 DTR 266/ 320 ITR 674/180 Taxman 623 (Delhi) (High Court) - Where the assessing officer

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

23,13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

23,13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce

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

23, 2023 Date of pronouncing the order : July 07, 2023 I.T.A No.299/Ran/2017, I.T.A No.123/Ran/2018 & C.O No.08/Ran/2018 M/s Bharat Coking Coal Ltd Assessment year: 2009-10 आदेश / ORDER संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg, Judicial Member: With this common order, we will dispose of revenue’s appeal ITA No.299/Ran/2017 and corresponding cross-objections by the assessee bearing