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

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

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

M/S. HIMACHAL CONSTRUCTION CO. PVT. LTD,JAMSHEDPUR vs. ITO, WARD NO.1(5), JAMSHEDPUR

In the result, the appeal filed by the assessee is dismissed

Bench: Dr. Manish Borad & Sonjoy Sarma

disallowance and estimated the profit arbitrarily @ 8% of the gross receipts. Under these circumstances I tend to agree with the submission of the appellant and therefore by squarely relying on the decisions cited by the appellant (supra), the AO is directed to compute profit @ 8% of Gross receipts after allowing depreciation. In other words the net addition sustained is Rs.26

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

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]

disallowed the brought forward unabsorbed depreciation loss of Rs. 944,77,29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90

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]

disallowed the brought forward unabsorbed depreciation loss of Rs. 944,77,29,240/- for the AYs 1996-97, 1997-98 & 1999- 2000 by recalculating the brought forward unabsorbed depreciation / loss of the preceding years at Rs. 942,13,59,936/- (AY 2000-01 to AY 2005-06) instead of Rs. 1886,90

GOLDEN GOENKA COMMERCE PVT. LTD.,,KOLKATA vs. ACIT CIRCLE-2(1),, JAMSHEDPUR

In the result, the appeal filed by the assessee stands allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

disallowed set-off of certain losses against capital gains and finally assessed the total income at ₹4,89,67,090 vide order dated 21.12.2018. 4. On appeal, the learned CIT(A) sustained the addition holding that in absence of compliance to summons under section 131 of the Act and on the basis of the identity, creditworthiness and genuineness

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

Section 37(1) of the Income-tax Act, 1961 - Business expenditure\nAllowability of (Welfare expenses of employees) - Assessee-\ncompany was engaged in business of coal mining It claimed\nexpenses incurred towards welfare of of its employees like canteen,\nhostels, etc. business expenditure Commissioner disallowed same\non ground that said expenditures had not been properly explained\nand that assessee

DCIT CIR-1, RANCHI vs. CCL, 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 CIR-1, RANCHI vs. CCL, 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 CIR-1,, RANCHI vs. CCL, 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

CCL,RNCHI vs. ACIT 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

CCL,RANCHI vs. ACIT 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. CENTRAL COALFIELDS 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

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

KAMESHWAR ALLOYS AND STEELS PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 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 Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

section 68 of the Act as unexplained cash credit and also disallowed ₹14,182 towards penal expenses. 3. Aggrieved the order of the Assessing Officer, the assessee preferred an appeal before the CIT(A), where the Ld. Commissioner of Income-tax (Appeals) sustained the addition of ₹2,00,00,000. 4. Dissatisfied with the order

ACIT CIR-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