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. Appellant 2. Respondent 3. Pr. CIT 4

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

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)

4. Dissatisfied with the order of the CIT(A) assessee is in appeal before this tribunal. Before us, the assessee filed an additional legal ground challenging the validity of the reassessment proceedings on the ground that the approval obtained under section 151 of the Act for issuance of notice under section 148 of the Act was granted in a mechanical

SRI SANJAY KUMAR SHARDA,WEST SINGHBHUM vs. ACIT, C.C.-1, RANCHI

Appeal is allowed

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Assessment Year:2016-17 बनाम Sri Sanjay Kumar Sharda Acit, Central Circle-1, Ranchi / Barajamda, West Singhbhum, V/S. Jharkhand-833221. Pan No.Ahwps4875Q अपीलाथ" /Appellant ""यथ" /Respondent ..

11. Hon'ble Jurisdictional High Court in the case of PCIT V/s Kulwant Singh Bhatia (supra) dealt the issue of defective notice issued u/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 SHRI RAM POWER & STEEL PVT. LTD.,,KOLKATA vs. ACIY, C.C.1, RANCHI

Appeal is allowed

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2016-17

11. Hon'ble Jurisdictional High Court in the case of PCIT V/s Kulwant Singh Bhaiia (supra) dealt the issue of defective notice issued ii]» 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

OM PRAAKSH SINGH,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, appeal filed by the assessee is allowed

Bench: Shri S.S, Godara, Jm & Dr. A.L. Saini, Am Om Prakash Singh Vs. Dcit, Circle-1, Ranchi Sankalp, East Jail Road, Ranchi- 834001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agkps0300D (अपीलाथ" /Appellant) .. (""थ" / Respondent)

reassessment proceedings was claimed to be started by assessing officer on 24.12.2014 which is also beyond four years. 8. It is a settled position of law that where an assessment under sub-section 3 of section 143 has been made for the relevant assessment year, then no action shall be taken under 5 Om Prakash Singh Assessment Year

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

11,530/-. Pertinent to state that the assessment was reopened on the ground that the employees contribution to PF and ESI was deposited after the due date in several months and therefore Rs. 46,00,057/- has escaped assessment. The AO added Rs. 9,27,523/- to the income of the assesse in the assessment framed u/s 143(3) r.w.s

MISRILALL JAIN & SONS,SINGHBHUM WEST vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result the appeal filed by the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 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 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

section 148 of the Act and the same was accepted. Therefore, no further additions could be made beyond the income forming part of the reasons recorded, and the reassessment order making additions over and above the returned income is bad in law. Besides that the interest income of ₹4,75,23,253 arose from fixed deposits maintained as security with

RINKI SINGH ,JAMSHEDPUR TELCO vs. ITO WARD 2(1) JAMSHEDPUR, JAMSHEDPUR

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Rinki Singh, I.T.O., Flat No. 5703, Prakirti Shanti Valley Ward 2(1), Vs. Society, Hurlung, Telco, Jamshedpur. Jamshedpur-831004 (Jharkhand) Pan No. Issps 0698 A Appellant/ Assessee Respondent/ Revenue

reassessment by the learned ITO." 2. Facts of the case are that the assessment under Section 147 read with section 144B of the Income Tax Act, 1961 (in short, the Act) was passed on 30/03/2023 on a total income of ₹ 23,56,250/- in which addition of Rinki Singh Vs ITO ₹ 21,11,500/- was added under Section

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

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 by the assessee that at different places, work was going on, where labours were hired

SURESH KUMAR AGARWAL,DHANBAD vs. ACIT,C.C., DHANBAD

In the result, all the three appeals of the assessee are allowed

11. The second issue of my adjudication is that as to whether the ld. AO was correct in imposing penalty by pressing into service of Explanation 5 to Section 271(1)(c) of the Act. In the present case, from, the reassessment order dated 22.03.2016 as well as the impugned penalty order dated 30.09.2016, I observe that the amount

SURESH KUMAR AGARWAL,DHANBAD vs. ACIT,C.C., DHANBAD

In the result, all the three appeals of the assessee are allowed

11. The second issue of my adjudication is that as to whether the ld. AO was correct in imposing penalty by pressing into service of Explanation 5 to Section 271(1)(c) of the Act. In the present case, from, the reassessment order dated 22.03.2016 as well as the impugned penalty order dated 30.09.2016, I observe that the amount

SURESH KUMAR AGARWAL,DHANBAD vs. ACIT,C.C., DHANBAD

In the result, all the three appeals of the assessee are allowed

11. The second issue of my adjudication is that as to whether the ld. AO was correct in imposing penalty by pressing into service of Explanation 5 to Section 271(1)(c) of the Act. In the present case, from, the reassessment order dated 22.03.2016 as well as the impugned penalty order dated 30.09.2016, I observe that the amount

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT,CIRCLE-1(1),, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

section 143(2) was issued against return under 148.” 4. On confrontation of these additional grounds for their admission, Ld. Sr. DR has not raised any objection. Accordingly, the same were admitted for adjudication. 5. Since additional grounds are on the jurisdictional issue, we are inclined to take up the same first. First three additional grounds relate to approval

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

section 143(2) was issued against return under 148.” 4. On confrontation of these additional grounds for their admission, Ld. Sr. DR has not raised any objection. Accordingly, the same were admitted for adjudication. 5. Since additional grounds are on the jurisdictional issue, we are inclined to take up the same first. First three additional grounds relate to approval

M/S TENUGHAT EMTA COAL MINES LTD.,,RANCHI vs. ITO,WARD-3(2), RANCHI

In the result, both the appeals of the assessee are allowed

Bench: S/Shri Chandra Mohan Garg & Laxmi Prasad Sahu

reassessment proceedings u/s.147 of the Act and thus, he is empowered to issue notice u/s.148 of the Act to the assessee calling his stand on the return of income. Accordingly, Ground Nos.2 to 2.2 of the assessee are dismissed. 9. Ground Nos.3 & 4 of appeal for the assessment year 2007-08 are as under: “ 3. That the CIT(A) grossly

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. BENKO TRADERS PRIVATE LIMITED, KOLKATA

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

11. On this issue, the Id. AR submitted that the assessee had received the said loans in the ordinary course of business, duly recorded them in the books of accounts, and had repaid the same during the year itself. The assessee had also deducted TDS on the interest paid under section 194A of the Act and deposited

SMT PRITI PALRIWAL,RANCHI vs. ITO WARD 2(2), RANCHI

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

SRI KAMAL KUMAR PALRIWAL,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, all the captioned appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, in respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under section 132 or requisition under section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened