SURYA REALCON PRIVATE LIMITED,SARAIDHELA, DHANBAD vs. DCIT, AAYAKAR BHAWAN, DHANBAD

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

2) of section 139 of the Act. In other words, if a return is filed within the time specified in sub-section (4) of section 139 of the Act and the option contemplated by the Explanation to section 11(1) is exercised in writing along with such return, the requirements of the Explanation to section 11(1) would stand satisfied

SANJAY CHAWLA,CHAIBASA vs. PR. CIT, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaysanjay Chawla, Pr.C.I.T., Sentola, Chaibasa-833201 (Jharkhand) Ranchi. Vs. Pan No. Acmpc 6808 J Appellant/ Assessee Respondent/ Revenue

2. The grant of license is on the basis of e-tender basis allotted by State Govt. to sell the foreign & Country liquor, in retail & at particular area earmarked by them only. 3. That successful shopkeepers to whom license allotted has to purchase the liquor only from the State Govt. owned agency I.e. from "Jharkhand State Beverages Corporation Ltd., Ranchi

MECON LTD ,RANCHI vs. DCIT CIR-2 , RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

disallowance under Explanation 2 to Section 37(1) comes into play, but, as for latter, there is no such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be "wholly and exclusively for the purposes of business". There is no dispute that the expenses in question

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’).

8 I.T.A. No.63/Ran/2022 Assessment Year: 2018-19 Nepal Chandra Dey (iv) disallowance of expenditure indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction claimed under sections 10AA, 80- IA, 80-IAB, 80-IB, 80-IC, 80-ID or section 80-IE, if the return is furnished beyond

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]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

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]

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

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 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. 8

MECON LIMITED,RANCHI vs. ACIT CIRCLE-2 , RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

disallowance under Explanation 2 to Section 37(1) comes into play, but, as for latter, there is no such disabling provision as long as the expenses, even in discharge of corporate social responsibility on voluntary basis, can be said to be "wholly and exclusively for the purposes of business". There is no dispute that the expenses in question

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 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 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

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. 2,00,93,041 and consequential tax effect of Rs. 65,42,767/-. 4. Aggrieved by the order passed by the ld. PCIT under Section

M/S EKLAVYA ESTATE PVT.LTD.,RANCHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RANCHI, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Eklavya Estate Pvt. Ltd., D.C.I.T., H-95, Harmu Housing Colony, Central Circle-2, Vs. Ranchi-834002 (Jharkhand) Ranchi. Pan No. Aabce 5815 F Appellant/ Assessee Respondent/ Revenue

disallowance, 5) That lastly, we place reliance upon the following case laws:- DCIT vs. Chakradhar Contractors and Engineers (P.) Ltd. [2025] 171 taxmann.com 133 (Pune-Trib.) [26-12-2024] It is an admitted fact that the Assessing Officer in the assessment order has not specified as to under which limb of provisions of section 2704(2

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 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

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

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

section 32(2) as amended by Finance Act, 2001 and were available for carry forward and set off against the profits and gains of subsequent years without any limit whatsoever.” 8. In the light of the judicial precedents on the issue especially that of the Hon’ble Gujarat High court in the case of General Motors India Pvt. Ltd. (supra

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

8,25,86,586/- and ₹ 1,99,14,936/- were utilized against the revenue and capital expenditure respectively by the institute. The remaining ₹ 2,54,06,674/- were accumulated and set apart for the purpose as specified under Section 11(2) of the Act by the institute during the year under consideration. The appellant has claimed that the amount

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

disallowed under Section 37 read with section 40A(2b) of the Act on estimate basis being 20% of the expenditure claimed. The Ld. AR, then placed reliance on the decision made by Hon'ble ITAT Cuttack Bench in the case of M/s Ravi Metallics Ltd Vs PCIT Sambalpur in ITA No. 34/CTK/2021 dated 30/05/2022, wherein it was held as under