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

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

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

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

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

ITO EXEMPTION WARD , JAMSHEDPUR vs. ALL INDIA WOMEN'S CONFERENCE , JAMSHEDPUR

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

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

23,164/- levied under section 271(1)(c) of the Act. 4. At the outset, ld Authorised Representative of the assesse filed an order dated 12.10.2017 in the quantum appeal in ITA No.304 & 305/Ran/2014 for the assessment year 2010-11 and 2011-12 and submitted that as the very basis of addition regarding levy of penalty has been deleted

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 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

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

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 CIRCLE-1 , DHANBAD vs. M/S BHARAT COOKING COAL LTD , 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, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M Vs. Acit, Circle-1, Dhanbad & 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) 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 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / Order Per Bench : 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

SRI AJAY KUMAR AGARWAL,RANCHI vs. ITO,WARD-1(1), RANCHI

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

Bench: Shri S.S. Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.244/Ran/2018 ("नधा"रणवष" / Assessment Year: 2013-14)

section 23(3).” I find that the ld. Assessing Officer has been reasonable in making the disallowance. 7. Aggrieved the assessee is in appeal before us. 8. We have heard the ld. DR and perused the material available on record. We note that the ld. CIT(A) was not justified for making an ad hoc disallowance of Rs. 2

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

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)

disallowed under any circumstances. 2. As required in para 2 of your notice, we would like to bring to your notice that the assessee has claimed the following expenses under the head “Mines Development” Expense for a total of Rs. 2,31,97,746.00 during the relevant previous year 2011-12: Expenses Amount in (Rs.) Overburden Removal

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

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