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)

11 of the Income-tax (Appellate Tribunal) Rules, 1963 seeking admission of an additional legal ground, contending that the approval obtained under section 151 of the Act for issuance of notice under section 148 was never furnished to the assessee. Therefore, the reassessment proceedings are therefore bad in law. Further, the Assessing Officer adopted stamp duty valuation without referring

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

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) (Del) and various ITAT decisions quashing reassessment on identical facts. The Ld. AR in order to prove the fact he submitted copy of the approval granted u/s 151 of the Act is hereunder: 6. On the other hand, the learned DR supported the orders of the lower authorities and submitted that approval under section

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

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

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”).

6. We, after hearing the rival submissions and perusing the material available on record. First, we take up the legal issue which goes to the root of the matter and therefore, the same is required to be adjudicated at the threshold wherein the assessee challenged the validity of the reassessment proceedings on the ground that the notice issued 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

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

6,09,260/- from 2 Shiv Pd. Ram Vs ITO the SAIL, Bokaro Steel Plant during the period under consideration. Thus, the assessee, being the non-filer for the assessment year under consideration, reassessment proceedings was initiated against him and notice under Section 148 of the Act was issued on 05/04/2022 after obtaining the approval of the specified authority

URUSI RAHMAN,KADMA vs. ITO, JAMSHEDPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.257/Ran/2025 Assessment Year: 2017-18 Urusi Rahman….... …………….…….…............................……….……Appellant 88 New Rani Kodar, Line No.4, Po Kadma, Jamshedpur, Jharkhand- 831005. [Pan: Amxpr0867K] Vs. Ito, Jsr…..……………….....….…..….........……........……...…..…..Respondent Appearances By: Shri Shrawan Kr. Jha, Adv., Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 27.05.2025 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 Did Not File Any Return Of Income For The Assessment Year 2017–18. Subsequently, The Case Was Reopened Under Section 147 Of The Income-Tax Act, 1961 On The Basis Of Information Received By The Assessing Officer That The Assessee Had Purchased An Immovable Property For A Declared Consideration Of ₹10,00,000, Whereas The Value Adopted For Stamp Duty Purposes Was ₹25,75,000. It Was Alleged That The Provisions Of Section 56(2)(Vii)(B) Of The Act Were Applicable. Accordingly, Notice Under Section 133(6) Was Issued Calling Upon The Assessee To Explain The Reasons For Not Filing The Return Of Income & To Furnish Details Regarding The Purchase Of The Property. However, There Was No Compliance By The Assessee. Thereafter, Notice Under Section 148 Of The Act Was Issued After Obtaining The Requisite Prior Approval From The Competent Authority. During The Course

11, 2025 Date of pronouncing the order : December 18, 2025 ORDER Per Sonjoy Sarma, Judicial Member: This appeal filed by the assessee is directed against the order of the NFAC, Delhi (hereinafter referred to as “ld. CIT(A)”) dated 27.05.2025 passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”). 2. Brief facts

ABHISHEK GOURASARIA,JAMSHEDPUR vs. ACIT , JAMSHEDPUR

In the result, consequential assessment order also stands quashed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayabhishek Gourasaria, A.C.I.T., 118, Flat No. 2B, Surabhi Apartment, K Jamshedpur Vs. Road, Bistupur, Jamshedpur-831001. Pan No. Adwpg 2149 R Appellant/ Assessee Respondent/ Revenue

6,35,000/-through and 11,000/-in cash as booking Amount for the purchase of 2 Abhishek Gourasaria Vs ACIT flat No. G-1 of 700 sq. ft. in the apartment Krishnakunj, Bistupur, Jamshedpur. As per the seized documents cash was deposited by "Sohanna" allegedly related the name to my Father Shri Sohan Lal Gaurisaria. The Assessing Officer erred

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

SHRI SANJOG PRASAD,JAMSHEDPUR vs. ACIT,CIRCLE-3(1), JAMSHEDPUR

In the result, appeal of the assessee is partly allowed

Bench: Shri Chandra Mohan Gargआयकर अऩीऱ सं./Ita No.109/Ran/2019 (नििाारण वषा / Assessment Year :2012-2013) Shri Sanjog Prasad, Vs. Acit, Circle-3(1), H.No.493, B-Block, Sonari, Jamshedpur Jamshedpur-831011 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Acupp 8930 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Acit(Dr) सुनवाई की तारीख / Date Of Hearing : 23/05/2019 घोषणा की तारीख/Date Of Pronouncement 24/05/2019 आदेश / O R D E R This Appeal Has Been Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals), Jamshedpur, Dated 14.01.2019 Passed In First Appeal No.50/Jsr/2018-19 For The Assessment Year 2012- 2013. 2. The Assessee Has Raised The Following Grounds Of Appeal :- 1. For That The Assessment Being Completed U/S 147/143(3) Is Ab Initio Void & Illegal. The Subject Matter For The Initiation Of Proceeding U/S 147 Was Already Considered & Looked Into During The Course Of Scrutiny Assessment U/S 143(3). As Such, This Initiation Can Only Be Said To Be Change Of Opinion. As Such, Proceeding Being Initiated U/S 147 Is Ab Initio Void, Illegal & Fit To Be Deleted. 2. For That The Authorities Below Were Not Justified In Not Considering The Objection Raised By The Appellant Regarding The Initiation Of Proceeding U/S 147. There Was No Fresh Material Available On Record With The Ld. Ao To Suggest Any Escapement Of Income. As Such, The Proceeding Being Initiated Merely On Change Of Opinion Is Unjustified, Illegal & Fit To Be Deleted.

Section 147 & 148 of the Act on verification of bank statements of State Bank of India, therefore, initiation of reassessment proceedings are quite correct and valid. He also submitted that the second issue is pertaining to deemed rental income from house property at Jamalpur, which has escaped the assessment, therefore, the AO is empowered for initiation of reassessment proceedings. 11

VISION & VISION PRIVATE LIMITED,JAMSHEDPUR vs. ACUT/ DCIT CIRCLE 1, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.183/Ran/2025 Assessment Year: 2018-19 Vision & Vision Pvt. Ltd.…….……………............................……….……Appellant Block No.2, Ambika Tower, Main Road Shastri Nagar, Jamshedpur – 831005. [Pan: Aabcv5072B] Vs. Acit/Dcit, Circle-1, Jamshedpur ..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2025 Date Of Pronouncing The Order : November 19, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Principal Commissioner Of Income Tax (Pcit), Ranchi, Passed Under Section 263 Of The Income-Tax Act, 1961 (“The Act”) Dated 31.03.2025 For A.Y. 2018–19. The Assessee Challenges The Legality & Validity Of The Assumption Of Jurisdiction By The Pcit & The Consequent Revision Of The Reassessment Order Passed U/S 147 R.W.S. 144B Dated 27.03.2023. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income For A.Y. 2018–19 Declaring Total Income Of ₹11,95,030. The Return Was Initially Processed U/S 143(1). Later, Based On Information Shared By The Ddit (Investigation), Kolkata, It Was Alleged That The Assessee Had Received An Accommodation Entry Of ₹1,18,61,425 From M/S Kuldeepak Enterprises During The Year. On This Basis, The Ao Reopened The

11,95,030. The return was initially processed u/s 143(1). Later, based on information shared by the DDIT (Investigation), Kolkata, it was alleged that the assessee had received an accommodation entry of ₹1,18,61,425 from M/s Kuldeepak Enterprises during the year. On this basis, the AO reopened the I.T.A. No.183/Ran/2025 Vision & Vision Pvt. Ltd assessment

ROSHAN MAHESHWARI,JAMSHEDPUR vs. ITO,WARD-3(5), CHAIBASA

In the result, appeals filed by the assessee are allowed

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

6. That the AO as well as CIT(A) were not justified in passing the order in an exparte manner without appreciating the facts and giving reasonable opportunity of hearing. 7. For that the CIT(A) was not justified in confirming the estimate of net profit @ 5% of the gross receipts added by AO as against net profit @ 1.96% declared

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

M/S. GAURAV PALRIWAL (HUF),RANCHI vs. ITO WARD-1(3), 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