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

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 143

KULDIP SINGH,RANCHI vs. DCIT/ACIT, CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.180/Ran/2025 Assessment Year: 2014-15 Kuldip Singh…………………….……….……...................……….……Appellant The Avenue Vishnupuri Marg, Upper Burdwan Compound, Lalpur, Ranchi- 834001. [Pan: Agjps6921P] Vs. Dcit/Acit, Circle-1, Ranchi…...…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kailash Gautam, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 10, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 06.03.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

reassessment proceedings - It was noted that assessee had filed complete details of its share transactions in case of 'S' Ltd. at time of completion of assessment under section 143(3

INCOME TAX OFFICER, RANCHI, JHARKHAND vs. AMBA CARBONISATION PVT. LTD., RANCHI, JHARKHAND

In the result, the appeal of the revenue is dismissed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 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 Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

reassessment, the assessee had filed its return of income under section 139 of the Act. The case was selected for scrutiny, and assessment under section 143(3

M/S S.P ENTERPRISES,JAMSHEDPUR vs. DCIT, JAMSHEDPUR

In the result, appeals filed by the assessee are allowed and the

Bench: Shri N.S Saini & Pavan Kumar Gadale

Section 143(2) of the Act within prescribed time was wholly without jurisdiction and void ab-initio. Respectfully following the decisions quoted above, we hold the reassessment orders passed in pursuance to this notice u/s.148 of the Act is also bad in law. We, therefore, cancel the reassessment order dated 25.3.2013 passed u/s.144/147 of the Act for the assessment year

HIRALAL AGENCIES PVT. LTD.,,RANCHI vs. DCIT, CIRCLE-1, RANCHI

Appeal of the assessee is allowed

Bench: the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO.

reassessment on the ground that the notice under Section 148 dated 11.08.2017 was issued beyond four years from the end of the relevant assessment year (A.Y. 2011–12), even though the original assessment had been completed under Section 143(3

MARS MERCANTILES PVT.LTD.,DHANBAD vs. ASSISTANT COMMISSIONE OF INCOME TAX, CENTRAL CIRCLE, DHANBAD, DHANBAD

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

3) is bad in law to the extent that no addition has been made in the order of assessment on basis of the reasons recorded for initiating proceeding u/s. 148.” 4. While taking the additional ground challenging the legality of the reassessment proceedings initiated u/s. 148 of the Act and the order passed u/s. 147 read with section 143

M/S. CCOMMERCIAL CARRIERS LTD,BALLYGUNGE, KOLKATA vs. PR. CIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.28/Ran/2021 Assessment Year: 2016-17 M/S Commercial Carriers Ltd.....................…...........................……….……Appellant 1F & G, Swinhoe Castle, Swinhoe Street, Ballygunge, W.B – 700019. [Pan:Aaacc6949F] Vs. Pcit, Ranchi……………..…..…..….…..….........……........……...…..…..Respondent Appearances By: Shri C M Roy, Ar, Appeared On Behalf Of The Appellant. Shri Rajib Jain, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 04, 2025 Date Of Pronouncing The Order : August 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 18.03.2021 Of The Principal Cit, Ranchi [Hereinafter Referred To As ‘Pcit’] Exercising Revision Jurisdiction U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Revising The Original Assessment Order Dated 26.12.2018 Passed Under Section 143(3) Of The Act. 2. Brief Facts Of The Case That The Assessee Is A Company Engaged In The Transport & Infrastructure Business. During Assessment Proceedings, The Assessing Officer (Ao) Passed An Order Under Section 143(3), Determining The Total Income At ₹9,95,690, After Making Disallowances, Including ₹3 Lakhs On Trip Expenses & ₹6,95,692 Under Section 37 Of The Act. However, On Examination Of The Assessment Records, The Ld. Pcit Ranchi, Observed That Sundry Creditors Amounting To ₹2,42,35,736 Were Shown In The Audited Balance Sheet, But No Enquiry Or Verification Was Made During Assessment Proceeding & Similarly Issue Relating To Investment In Purchase Of Trucks & Trailers Amounting To ₹5,10,44,030 Was Recorded; However, The Assessee Had

3) of the Act. Therefore, it cannot be said that the AO failed to make any enquiry or that the assessment order was erroneous or prejudicial to the interest of revenue. Similarly, on the issue of purchase of trucks and trailers, no addition was made in the reassessment order under section 143

MANISH AGARWAL,BALLYGUNGE vs. ACIT, CENTRAL CIRCLE-2, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.16/Ran/2024 Assessment Year: 201-12 Manish Agarwal……….…………….…….…............................……….……Appellant 35A, Tirumala Apartment, Ballygunge Park, Kol- 700019. [Pan: Acdpa1176E] Vs. Acit, Central Circle-1, Ranchi......…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Sunit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 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 28.11.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Act Was Conducted In The Case Of The Assessee Group On 23.10.2019. Pursuant To The Said Search, The Assessing Officer (Ao) Issued A Notice Under Section 153A Of The Act Calling Upon The Assessee To File Its Return Of Income For Six Assessment Years Preceding The Year Of Search. In Response To The Notice Under Section 153A, The Assessee Filed Its Return Of Income For Assessment Year 2011–12, Declaring A Total Income Of ₹6,95,180/-. During The Course Of Assessment Proceedings, Several Statutory Notices Were Issued To The Assessee, Which

143(3) of the Act, determining the total income of the assessee at ₹17,83,757/-, by making the following additions of ₹10,52,217/- on account of alleged unexplained cash deposits, and ₹36,690/- on account of interest income. 3. Aggrieved by the assessment order, the assessee preferred an appeal before

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)

143(3) of the Act determining total income at ₹61,97,051. While completing the assessment, the Assessing Officer made addition of ₹30,00,000 under section 68 of the Act on account of unsecured loans, rejected the books of account and estimated profit at the rate of 8%, made further additions of ₹1,21,499 on account of sundry

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

3. That the reasons were not recorded on the date of issuance of notice under 148. 4. That the entire assessment is null and void as no notice under 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

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

3. That the reasons were not recorded on the date of issuance of notice under 148. 4. That the entire assessment is null and void as no notice under 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

M/S HEAVEN CONSTRUCTION AND ENGINEERING PVT. LTD.,,RANCHI vs. ITO,WARD-!(1), RANCHI

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri S.S. Godara, Jm] I.T.A No. 226/Ran/2018 Assessment Year : 2010-11 M/S Heaven Construction & Engineering –Vs- Ito, Ward-1(1), Ranchi Pvt. Ltd. [Pan: Aabch 9922 N] (Appellant) (Respondent)

reassessment framed u/s 147 read with section 143(3) of the Act dated 30.12.2013 is not a valid order and the same

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

143(2) and 142(1) were issued and complied with. According to the AO, income of ₹1,64,60,100 representing sale proceeds of shares was to be treated as unexplained cash credit under section 68 of the Act, along with commission expenditure of ₹3,29,202 @2% under section 69C, and unsecured loans of ₹59,00,000 received from

JAISWAL STEEL INDUSTRIES PRIVATE LIMITED,JAMSHEDPUR vs. ITO WARD 2(1), JAMSHEDPUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.284/Ran/2024 Assessment Year: 2016-17 Jaiswal Steel Industries Pvt. Ltd. ….…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831006. [Pan: Aabcj4471C] Vs. Ito, Ward-2(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 02.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

reassessment proceedings were initiated and the assessment was completed by the Assessing Officer under section 147 read with section 143(3

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”).

143(3) of the Act and applying the principle of consistency, the interest income cannot be treated as income from other sources. With regard to the disallowance of expenses of ₹3,42,60,244, it was submitted that due to disputes among partners and attachment of the firm’s bank accounts by the Income Tax Department for earlier year demands

SHIV SHAMBHU IRON AND STEEL PRIVATE LIMITED,JAMSHEDPUR vs. ACIT CIRCLE 3(1), JAMSHEDPUR

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.286/Ran/2024 Assessment Year: 2016-17 Shiv Shambhu Iron & Steel Pvt. Ltd.…….…............................……….……Appellant Dropadi Bhawan, Station Road, Jugsalai, Jharkhand- 831002. [Pan: Aalcs7663M] Vs. Acit, Circle-3(1), Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 12.04.2024 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 Filed Its Return Of Income For The Assessment Year 2011–12 Declaring A Total Income Of ₹30,17,990. The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Of The Act Was Completed Determining The Total Income At ₹39,08,910. Subsequently, Based On Information Received, It Was Noticed That The Assessee Company Had Shown Receipt Of ₹1,49,00,000 Comprising Share Capital Of ₹14,90,000 & Share Premium Of ₹1,34,10,000. On The Basis Of This Information, The Assessing Officer Issued Notice Under Section 148 Of The Act. In Response To The Notice, The

143(3) read with section 147 of the Act, determining the total income at ₹1,88,08,910. 3. Aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals). However, the Ld. CIT(A) dismissed the appeal and sustained the order of the Assessing Officer. 4. Before the Tribunal, the assessee contended that the reassessment

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.467/Ran/2024 Assessment Year: 2014-15 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 20, 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 09.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

reassessment proceedings, the assessee remained largely non-compliant, and therefore, the Assessing Officer was left with no alternative but to complete the assessment ex parte under section 144 read with section 147 of the Act. The Assessing Officer determined the total income of the assessee at ₹7,34,14,430, making the following addition