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

35,96,159/-, it means the assessee had debited more than what was allowable under the said Section and therefore, the same should have been disallowed while passing the order under Section 143(3) of the Act. Since the Assessing Officer has failed to do so, the said omission resulted in short computation of income of Rs. 2

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

NATIONAL UNIVERSITY OF STUDY AND RESEARCH IN LAW,RANCHI vs. ASST. DIRECTOR OF INCOME TAX ,CPC, BENGALURU

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

Bench: Shri Pradip Kumar Choubey & Shri Ratnesh Nandan Sahay(Virtual Hearing) National University Of Study & Assistant Director Of Research In Law, Ranchi, Income Tax, Vs. Nusrl Campus, Pithoria Road, P.O- C.P.C., Bangaluru. Burku At Nagri, Jharkhand. Pan No. Aaajn 0847 Q Appellant/ Assessee Respondent/ Revenue

disallowed. 6. Aggrieved by the above order of CPC, the appellant filed appeal before the ld. CIT(A), who vide the impugned order, allowed the accumulated and set apart fund under Section 11(2) of the Act. However, the capital expenditure of ₹ 1,99,14,936/- escaped the attention of the ld. CIT(A) and as a result, the said

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

35,40,000\nProvisions Toward NCWA VIII\n2,13,49,00,000\nMine Closure Expenses\n19,85,73,000\n1,21,53,000\nCSR Expenses - Welfare\nu/s 14A\nPA\nDisallowance of Prior Period Expenses\n1 Prior Period Expenses as per Note 32 of\nAnnual Report\n14,79,92,000\n2,21,98,000\n91,73,000\n12 Prior period

M/S MANIKARAN POWER LTD,RANCHI vs. ACIT, CIRCLE-2, RANCHI

In the result, the appeal of the assessee in ITA No

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 01/Ran/2025 (Assessment Year: 2022-23) A.C.I.T., Manikaran Power Limited, Central Circle-2, Manikaran Tower, Kilburn Colony, Vs. Ranchi. P.O. Hinoo, Ranchi-834002 (Jharkhand) J.C.I.T. (In Situ), Pan No. Aaecm 4555 F Ranchi. Revenue/ Appellant Respondent/ Assessee Manikaran Power Limited, A.C.I.T., Manikaran Tower, Kilburn Colony, Central Circle-2, Vs. P.O. Hinoo, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Aaecm 4555 F Revenue/ Appellant Respondent/ Assessee

35,77,52,226/- from any of the sellers of power. It was a submission that the said addition itself was not called for much less under Section 37(1) or Section 68 of the Act. The ld. AR had also placed before us the copy of the purchase register as also the sales register to show that the quantity

SHIV PRASAD RAM,BOKARO vs. ASSESSING OFFICER, BOKARO

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Shiv Prasad Ram, I.T.O., Near Petrol Pump, Sector-9/A, Basanti Ward 3(1), Vs. More, Sector-Ix, S.O. Alkusa, Bokaro. Bokaro-827009 (Jharkhand) Pan No. Aqepr 2909 K Appellant/ Assessee Respondent/ Revenue

disallowing the deduction under Chapter VI-A (Section 80C). The Appellant claimed a deduction of ₹1,50,000, which is allowable under the law. However, only ₹51,547 was allowed based on the employer's Form 16. Fixed deposits (FDs) made for a tenure of 5 years or more with a scheduled bank were eligible for deduction under Section

SHAH BROTHERS,CHAIBASA vs. ACIT CENTRAL CIRCLE-1, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayshah Brothers, A.C.I.T., Thana Lane, Chaibasa-833201 Central Circle-1, Vs. (Jharkhand) Ranchi. Pan No. Aazfs 7498 F Appellant/ Assessee Respondent/ Revenue

Section 143(3) r.w.s. 263 wherein the Assessing Officer took the stand that Rajshila Nirman Pvt. Ltd. was not existent at the given address and Rajshila Nirman Pvt. Ltd. did not have the machinery/excavation machinery to carryout the development of mining area. It was a submission that consequently the Assessing Officer disallowed the expenditure

M/S. CCOMMERCIAL CARRIERS LTD,BALLYGUNGE, KOLKATA vs. PR. CIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.28/Ran/2021 Assessment Year: 2016-17 M/S Commercial Carriers Ltd.....................…...........................……….……Appellant 1F & G, Swinhoe Castle, Swinhoe Street, Ballygunge, W.B – 700019. [Pan:Aaacc6949F] Vs. Pcit, Ranchi……………..…..…..….…..….........……........……...…..…..Respondent Appearances By: Shri C M Roy, Ar, Appeared On Behalf Of The Appellant. Shri Rajib Jain, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 04, 2025 Date Of Pronouncing The Order : August 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 18.03.2021 Of The Principal Cit, Ranchi [Hereinafter Referred To As ‘Pcit’] Exercising Revision Jurisdiction U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Revising The Original Assessment Order Dated 26.12.2018 Passed Under Section 143(3) Of The Act. 2. Brief Facts Of The Case That The Assessee Is A Company Engaged In The Transport & Infrastructure Business. During Assessment Proceedings, The Assessing Officer (Ao) Passed An Order Under Section 143(3), Determining The Total Income At ₹9,95,690, After Making Disallowances, Including ₹3 Lakhs On Trip Expenses & ₹6,95,692 Under Section 37 Of The Act. However, On Examination Of The Assessment Records, The Ld. Pcit Ranchi, Observed That Sundry Creditors Amounting To ₹2,42,35,736 Were Shown In The Audited Balance Sheet, But No Enquiry Or Verification Was Made During Assessment Proceeding & Similarly Issue Relating To Investment In Purchase Of Trucks & Trailers Amounting To ₹5,10,44,030 Was Recorded; However, The Assessee Had

disallowances, including ₹3 lakhs on trip expenses and ₹6,95,692 under section 37 of the Act. However, on examination of the assessment records, the Ld. PCIT Ranchi, observed that Sundry creditors amounting to ₹2,42,35

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

RAJESH JALAN,DHANBAD vs. DCIT/ACIT, CIRCLE-1, DHANBAD

The appeal of the assessee is allowed in full

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

2. Addition of ₹20,86,500/- under Section 69A of the Act alleged unexplained investment in capital. 3. The CIT(A) granted partial relief but sustained the above additions, against which the assessee is now in appeal before us. Addition under Section 68 – ₹7,40,000/- (Unsecured Loan) The Assessing Officer observed that the assessee had received unsecured loans aggregating

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”).

35,493 were made I.T.A. No.284/Ran/2024 Jaiswal Steel Industries Pvt. Ltd. on account of unexplained money under section 69A, unexplained investment under section 69 and disallowance of depreciation. 3. Aggrieved by the assessment order, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals). However, the appeal was dismissed by the Ld. CIT(A) due to non-compliance

CCL LTD ,RANCHI vs. DCIT CIRCLE-1, RANCHI

Section 14A of the\nAct was in existence and the some disallowances were called for. It was\nsubmitted that the disallowance should be proportionate to the investment\nmade.\n33. In rejoinder, Id. AR submitted that the bonds were on account of\nsecuritization of the debts. It was the submission that in the earlier years\nthe Id.CIT(A) has held this

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

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\nis dismissed

disallowed by\nthe Assessing Officer, establishing mens rea in assessee's approach.\n5. The CIT(A) failed to appreciate that the assessee is aided by a battery of CAs\nand advocates, still it deliberately filed inaccurate particulars of income.\n6. Other grounds, if any, will be raised at the time of hearing.\"\n2. The appeal of the assessee, bearing

CCL,RANCHI vs. DCIT CIR-1, RANCHI

Section 14A of the\nAct was in existence and the some disallowances were called for. It was\nsubmitted that the disallowance should be proportionate to the investment\nmade.\n33. In rejoinder, Id. AR submitted that the bonds were on account of\nsecuritization of the debts. It was the submission that in the earlier years\nthe Id.CIT(A) has held this

M/S JHARKHAND STATE FOREST DEVELOPMENT CORPORATION LIMITED ,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 No.33/Ran/2018 (निि ारण वर्ा / Assessment Year :2013-2014) M/S Jharkhand State Forest Vs. Dcit, Circle-1, Ranchi Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H & आयकर अपील सं./Ita No.38/Ran/2018 (निि ारण वर्ा / Assessment Year :2013-2014) Dcit, Circle-1, Ranchi Vs. M/S Jharkhand State Forest Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H & Cross Objection.03/Ran/2019 (निि ारण वर्ा / Assessment Year :2013-2014) (Arising Out Of Ita No.38/Ran/2018) M/S Jharkhand State Forest Vs. Dcit, Circle-1, Ranchi Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri J.P.Sharma, Advocate राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Per Bench :

section 43B of the Act. Hence, it was added back to the income of the AY 2013-14. Ground of Appeal A.Y. OPENING ROYALTY PAID CLOSING CHARGED IN P&L 2012-13 9,35,51,600 10,00,00,000 6,00,00,000 13,35,52,240 2013-14 13,35

DCIT CIRCLE-1 , RANCHI vs. M/S JHARKHAND STATE FOREST DEVELOPMENT CORPORATION LTD, 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 No.33/Ran/2018 (निि ारण वर्ा / Assessment Year :2013-2014) M/S Jharkhand State Forest Vs. Dcit, Circle-1, Ranchi Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H & आयकर अपील सं./Ita No.38/Ran/2018 (निि ारण वर्ा / Assessment Year :2013-2014) Dcit, Circle-1, Ranchi Vs. M/S Jharkhand State Forest Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H & Cross Objection.03/Ran/2019 (निि ारण वर्ा / Assessment Year :2013-2014) (Arising Out Of Ita No.38/Ran/2018) M/S Jharkhand State Forest Vs. Dcit, Circle-1, Ranchi Development Corporation Ltd. H/O Bms Electricals, Near Hinoo Bridge, Hinoo, Ranchi, Jharkhand-834002 स्थायी लेखा सं./Pan No. : Aabcj 1402 H (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri J.P.Sharma, Advocate राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 08/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Per Bench :

section 43B of the Act. Hence, it was added back to the income of the AY 2013-14. Ground of Appeal A.Y. OPENING ROYALTY PAID CLOSING CHARGED IN P&L 2012-13 9,35,51,600 10,00,00,000 6,00,00,000 13,35,52,240 2013-14 13,35