M/S NANDLAL KESHARDEO,RANCHI vs. ACIT, CENTRAL CIRCLE (1), RANCHI

In the result, this appeal filed by the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

11. Hon'ble Jurisdictional High Court in the case of PCIT Vis Kulwant Singh Bhatia (supra) dealt the issue of defective notice issued w/s 274 r.w.s. 271(1)(c) of the Act and Hon'ble court after relying judgment of Hon'ble Supreme Court in the case of CIT V/s Manjunatha Cotton Ginning Factory and CIT v/s SSA'S Emerald

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 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

11,67,32,000/- School & Institutions (v) Community Development & Environmental ₹ 12,24,87,000/- Expenditure (vi) Mines Closure Expenses ₹ 47,39,30,000/- (vii) CMPDIL expenses ₹ 56,93,18,000/- (viii) IICM Charges ₹ 2,37,61,000/- Total Additions/Disallowances ₹ 1,71,18,14,440/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD 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

11,67,32,000/- School & Institutions (v) Community Development & Environmental ₹ 12,24,87,000/- Expenditure (vi) Mines Closure Expenses ₹ 47,39,30,000/- (vii) CMPDIL expenses ₹ 56,93,18,000/- (viii) IICM Charges ₹ 2,37,61,000/- Total Additions/Disallowances ₹ 1,71,18,14,440/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with

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 is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

reassessment cannot be declared as invalid in the penalty proceedings." DCIT Vs M/s CCL & 1 Anr. The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD 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 Sahayd.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 M/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

reassessment cannot be declared as invalid in the penalty proceedings." DCIT Vs M/s CCL & 1 Anr. The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court

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 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

reassessment cannot be declared as invalid in the penalty proceedings." M/s CCL Vs DCIT & 1 Anr. The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, 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

reassessment cannot be declared as invalid in the penalty proceedings." M/s CCL Vs DCIT & 1 Anr. The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court

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 is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

reassessment cannot be declared as invalid in the penalty proceedings." The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court themselves and have been quoted above

DCIT,CIRCLE-1RANCHI, RANCHI vs. CENTRAL COALFIELD 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 Sahayd.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 M/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

reassessment cannot be declared as invalid in the penalty proceedings." The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court themselves and have been quoted above

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 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

reassessment cannot be declared as invalid in the penalty proceedings." The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court themselves and have been quoted above

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD 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

reassessment cannot be declared as invalid in the penalty proceedings." The order of the Hon'ble High Court in Manjunatha case (Supra), the factual and legal matrix of the case have been thoughtfully considered. The facts precedent to imposition of penalty in Manjunatha Cotton case have been outlined by the Hon'ble High Court themselves and have been quoted above

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

11, is being considered first. The facts of the present case, in brief, are that the appellant company is a Government of India Enterprise and one of the five subsidiaries of Coal India Ltd. The assessment under Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances were

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

In the result, appeal of the assessee is allowed

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

11 M/s CCL Vs DCIT (l) Only when no explanation is offered or the explanation offered is found to be false or when the assessee fails to prove that the explanation offered is not bonafide, an order imposing penalty could be passed. (m) If the explanation offered, even though not substantiated by the assessee, but is found to be bonafide

BADRINATH SALES PRIVATE LIMITED,ADITYAPUR, WEST SINGHBHUM vs. DCIT/ACIT CIRCLE 1 JSR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

reassessment is void ab initio. On merits, it was submitted\nthat books of account were never rejected under section 145(3)of the act\nand no discrepancy in physical stock was found. The additions were\nmade merely on suspicion due to fall in turnover. The Ld. AR stated that\nfor AY 2018–19, assessment was completed under section

SMITA,RANCHI vs. ITO WARD 3(4),, CHAIBASA

The appeal of the assessee is allowed

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

reassessment order passed under section 147 of the Act is quashed. 11. Accordingly, the appeal of the assessee is allowed. Order pronounced on 06.01.2026 (Ratnesh Nandan Sahay) (Sonjoy Sarma) Accountant Member Judicial Member Dated: 06.01.2026 AK, Sr. P.S. Copy of the order forwarded to: 1

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

1,94,84,010/-. Thereafter, the case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 22.06.2019. Again re-assessment was framed vide order dt. 25/10/2019 passed u/s 143(3) r.w.s. 147 of the Act assessing the income at Rs. 2,04,11,530/-. Pertinent to state that the assessment

BISHNU TRANSPORT COMPANY,DHANBAD vs. DCIT/ACIT, CIRCLE-1,, DHANBAD

In the result, the appeal of the assessee is allowed

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

11) held that mere affixing of “approved” without application of mind renders the reopening void ab initio. Similar view has been taken in United Electrical Co. (P) Ltd. v. CIT (258 ITR 317), wherein it was held that mechanical sanction under section 151 invalidates the reassessment proceedings. 8. Since, in the present case of the assessee the very foundation

ACIT, CC, DHANBAD, DHANBAD vs. LAL BAHADUR SINGH, DHANBAD

In the result, appeals of the assesses are allowed and appeals of the revenue are dismissed

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.90 To 94/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Shri Kumbh Nath Singh, Vs Dcit, Central Circle, Dhanbad Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.268 & 269/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 & 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Kumbh Nath Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1598 K & आयकर अपील सं./Ita Nos.95 To 99/Ran/2024 (निि ारण वर्ा / Assessment Years :2008-2009 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Bharat Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Bcpps 1599 J & आयकर अपील सं./Ita Nos.100 To 106/Ran/2024 (निि ारण वर्ा / Assessment Years :2006-2007 To 2012-2013) Vs Dcit, Central Circle, Dhanbad Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D & आयकर अपील सं./Ita Nos.265 To 267/Ran/2024 (निि ारण वर्ा / Assessment Years :2010-2011 To 2012-2013) Acit, Central Circle, Dhanbad Vs Shri Lal Bahadur Singh, Simla Bahal Cilliery, Jharia, Dhanbad-828111 स्थायी लेखा सं./Pan No. : Aydps 0747 D (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate & Shri Sanjay Chatterjee, Ar राजस्व की ओर से /Revenue By : None(Adjournment Petition Filed) सुनवाई की तारीख / Date Of Hearing : 09/10/2025 घोषणा की तारीख/Date Of Pronouncement : 09/10/2025

reassessment of the Return submitted by the assesse for the Assessment Year, 2003-2004 shall be deemed to be completed only on 05-04-2007 when the assessment order was served/ communicated to the representative of the assesse and the same was not completed within the period prescribed under section 153(2) of the Act. ***** [13] That apart