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

13,64,500/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide the impugned penalty order imposed a penalty of ₹ 69,68,01,600/- @ 150% of the tax sought to be evaded

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

13,64,500/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide the impugned penalty order imposed a penalty of ₹ 69,68,01,600/- @ 150% of the tax sought to be evaded

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

13,40,000/- being 150% of the total tax sought to be evaded. Being aggrieved with the penalty order, an appeal was filed before CIT(A) who vide the impugned order dated 15/03/2024, partly allowed the appeal filed by the assessee. The CIT(A) NFAC though dismissed the legal ground challenging the validity of the notice issued U/s 274 r.w.s

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

13,40,000/- being 150% of the total tax sought to be evaded. Being aggrieved with the penalty order, an appeal was filed before CIT(A) who vide the impugned order dated 15/03/2024, partly allowed the appeal filed by the assessee. The CIT(A) NFAC though dismissed the legal ground challenging the validity of the notice issued U/s 274 r.w.s

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

13,00,000/- (vi) CMPDIL expenses ₹ 51,68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (viii) Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice

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

13,00,000/- (vi) CMPDIL expenses ₹ 51,68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (viii) Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice

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." 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 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

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

13,000/- (vi) CMPDIL expenses ₹ 43,53,60,000/- (viii) IICM Charges ₹ 2,35,40,000/- Total Additions/Disallowances ₹ 97,77,17,000/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

13,000/- (vi) CMPDIL expenses *43,53,60,000/- (viii) IICM Charges * 2,35,40,000/- Total Additions/Disallowances * 97,77,17,000/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide

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

13,49,00,000/- Total Additions/Disallowances ₹ 2,56,30,71,000/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section 271(1)(c) of the Act and finally, the Assessing Officer vide the impugned penalty order imposed a penalty

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

B) with retrospective effect and by virtue of the amendment, the assessing officer has initiated the penalty by properly recording the satisfaction for the same? (3) Whether on the facts and in the circumstances of the case, the Tribunal was justified in deciding the appeals against the Revenue on the basis of notice issued under Section 274 9 M/s Nandlal

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 ..

B) with retrospective effect and by virtue of the amendment, the assessing officer has initiated the penalty by properly recording the satisfaction for the same? (3) Whether on the facts and in the circumstances of the case, the Tribunal was justified in deciding the appeals against the Revenue on the basis of notice issued under Section 274 without taking into

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

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

b), on or before such date, in the books of account, if any, maintained by him for any source of income or such income is otherwise disclosed to the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner] before the said date ; or (2) he, in the course of the search, makes a statement under sub- section

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

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

b), on or before such date, in the books of account, if any, maintained by him for any source of income or such income is otherwise disclosed to the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner] before the said date ; or (2) he, in the course of the search, makes a statement under sub- section

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

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

b), on or before such date, in the books of account, if any, maintained by him for any source of income or such income is otherwise disclosed to the [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner] before the said date ; or (2) he, in the course of the search, makes a statement under sub- section