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

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

Bench: Shri Sanjay Garg & Shri Manish Boradi.T.A. No.130/Ran/2018 Assessment Year: 2014-15 M/S Bharat Coking Coal Ltd…………..…...…......................……...…..….. Appellant Finance Directorate, Ground Floor, Koyla Bhawan, Koyla Nagar, Dhanbad-826005. [Pan: Aaacb7934M] Vs. Acit, Circle-1, Dhanbad…..……………………….……….…………….. Respondent Appearances By: Shri M. K. Choudhary, Advocate, Appeared On Behalf Of The Appellant. Shri Saumyajit Das Gupta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 26, 2022 Date Of Pronouncing The Order : September 20, 2022 Order Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 20.09.2017 Of The Commissioner Of Income Tax (Appeals), Dhanbad [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

section 201. 4. That in view of the aforesaid circular of the CBDT, the consequential relief of aforesaid addition of Rs.132,20,00,000/- be given. 3. A perusal of the impugned order of the CIT(A) in this case reveals that the assessee had not pressed the above issue relating to disallowance u/s 40(a)(ia) in respect

M/S USHA MARTIN LTD,KOLKATA vs. ACIT CIR-3, RANCHI

In the result, appeal of the assessee stands partly allowed for statistical purposes

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

disallowance as made by the AO is deleted in its entirety. Consequently, additional grounds No.1.4 and 1.5 of the assessee stand allowed. 8. Coming to additional Ground No.1.6, same is against interest under section 244A of the Act. No arguments have been placed. Ground No.1.7 is against interest under section 234 B and 234D, theseare consequential in nature. Consequently, additional

DY. COMMISSIONER OF INCOME TAX, JAMSHEDPUR vs. URANIUM CORPORATION OF INDIA LIMITED, JAMSHEDPUR

In the result, this appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Uranium Corporation Of India Jamshedpur. Limited, Vs. Turamardie Mines, Sundar Nagar, East Singhbhum-832107 (Jharkhand) Pan No. Aaacu 2207 N Appellant/ Assessee Respondent/ Revenue

disallowance was made by the ITA 205/Ran/2023 DCIT Vs. Uranium Corporation of India assessee itself. The ld. AR further submitted that the penalty should not be imposed under Section 270A of the Act for making inadvertent error which was subsequently rectified. The ld. AR in his submission submitted that even the show cause notice issued under Section 270A

M/S. CENTRAL COAL FIELDS LTD.,,RANCHI vs. ACIT/DCIT CIRCLE-1, RANCHI

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 37(1) of the Income-tax Act, 1961 - Business expenditure Allowability of (Welfare expenses of employees) Assessee- company was engaged in business of coal mining It claimed expenses incurred towards welfare of of its employees like canteen, hostels, etc. business expenditure Commissioner disallowed same on ground that said expenditures had not been properly explained and that assessee

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’).

section 36(1)(va) is applicable from 1st April 2022, but the same was not taken into consideration and the appeal was rejected.” 5. A perusal of the above grounds of appeal and statement of facts would show that the only issue raised in this appeal is relating to the disallowance

M/S STROKES ADVERTISING PVT. LTD.,,RANCHI vs. DCIT,C-2, RANCHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.81/Ran/2019 (नििाारण वषा / Assessment Year :2013-2014) M/S Strokes Advertising Pvt Ltd Vs. Dcit, Circle-2, Ranchi C/O Sri Vinay Kumar Jalan, M/S O.P.Jalan & Associates Consultants Llp, 48 Cart Sarai Road, Upper Bazaar, Ranchi, Jharkhand, Pin-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aancs 6471 M (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Vinay Kumar Jalan, Fca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 24/05/2019 घोषणा की तारीख/Date Of Pronouncement 26/07/2019 आदेश / O R D E R This Appeal Has Been Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals), Ranchi, Jharkhand, Dated 31.10.2018 Passed In First Appeal No.Cit(A), Ranchi/10077/2017-18 For The Assessment Year 2013-2014. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Under The Facts & Circumstances Of The Case The Ld. Cit(A) Erred In Confirming The 50% Of Total Disallowance Made By The Ld. Assessing Officer Amounting To Rs.2,53,884/- With Respect To The Amounts Debited In The P&L Account Relating To Fuel Expenses, Fabrications Works, Mounting Of Flex & Site Expenses 2. Under The Facts & Circumstances Of The Case The Ld. Cit(A) Erred In Confirming The Addition Made By The Ld. Assessing Officer Amounting To Rs.6,47,400/ Considering It To Be Commission Paid Without Deduction Of Tds.”

5% of the site expenses. The total disallowance under these heads totals to Rs.2,53,884/-. The AR has represented that the case of the appellant is covered under tax audit u/s.44AB and the AO has made estimated disallowances which is not correct. As per the Assessment Order, the AO has stated that the appellant could not produce

K M MEMORIAL HOSPITAL & RESERCH CENTRE (P) LTD,BOKARO vs. ACIT, CIRCLE-1,, HAZARIBAG

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

disallowed the entire amount under Section 40(a)(ia) of the Act and added back to the total income of the assessee. 5

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

disallowed under Section 37(1) of the Act. It was a submissions that on appeal, the ld. CIT(A) held that in respect of the issue of bogus purchases, the same could not be considered under Section 68 of the Act and the same was liable to be considered under Section 37(1) of the Act. It was a submission

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

disallowance relying on various case laws referred to in the order of the ld. CIT (Appeals). 1.9 For that the amendment brought in by the Finance Act, 2021 in Sections 36(1)(va) and 43B of the Act by way of inserting Explanation 2 and Explanation 5

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

5% of Rs. 7,19,23,183/- comes to Rs. 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

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

disallowance of ₹14,38,359 towards diesel allowance, wherein the CIT(A) changed the applicable provision from section 14A to section 40(a)(ia) without issuing any notice or granting opportunity of being heard to the assessee. 4.1 The learned counsel for the assessee further submitted that the CIT(A) erred in enhancing the addition by making an addition

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

section 194C of the Income Tax Act and, therefore, he disallowed both the items. 11. On due consideration of the facts and circumstances, we are of the view that the Revenue Authorities are not justified in making the above disallowance because on purchase of material, no TDS was required to be deducted by the assessee. Similarly it was submitted

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

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)

5. Subsequently, Ld PCIT has again exercised his jurisdiction under section 263 of the Act (hereinafter referred to as the “second 263 order”) to revise the original assessment order passed by the assessing officer under section 153A/143(3) dated 28.12.2016. The second 263 order was passed by the ld PCIT on 28.03.2019 observing as follows: “Subsequently, on a careful examination

MUSKAN HOSPITAL &RSEARVH CENTRE ,BOKARO vs. DCIT CIRCLE-3 , BOKARO

In the result, appeal of the assessee is partly allowed

Bench: Shri N.S Sainiassessment Year : 2014-15

disallowed under section 43B or under section 36(1)(va) - Whether SLP against said impugned order was to be dismissed - Held, yes [Para 2] [In favour of assessee]” 8. Respectfully following the decision of Hon’ble Supreme Court in the case of Rajasthan State Beverages Corporation Ltd. (supra), I set aside the orders of lower authorities and delete the addition

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

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

5. The Assessing Officer, however, was not convinced with the explanation offered by the assessee and disallowed a sum of ₹ 121,08,01,000/- under the head "under loading charges" under Section

DCIT CIRCLE-1, DHANBAD vs. BHARAT COKING COAL LTD.,, DHANBAD

In the result, this appeal of revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

5. The Assessing Officer, however, was not convinced with the explanation offered by the assessee and disallowed a sum of ₹ 121,08,01,000/- under the head "under loading charges" under Section

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

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

Section 1 Unabsorbed depreciation - covereed by ITAT order Dt. 31.03.2023 of AY 2008-09 u/s 143(3) 263/143(3) 147/143(3) 2,30,09,91,962 3 Contractual Expenses unpaid liability disallowed 29,00,32,000 5