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

4. In our view, since the matter is covered by judgment of the Division Bench of this Court, we are of the opinion, no substantial question of law arises in this appeal for determination by this Court. The appeal is accordingly dismissed" In the earlier case of Manjunatha Cotton and Ginning Factory (supra) their lordship had observed as under- "Notice

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

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

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

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

4 AY: 2012-13 Kross Limited years period of limitation shall run from the end of financial year in which the original assessment was framed and not from the end of financial year in which the reassessment was framed when the issue on which the assessment was revised was not subject matter of reassessment proceedings. The ld. A.R. also submitted

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.

Section 144 of the Act. 3. Dissatisfied with the order of Ld. AO preferred an appeal before the Ld. CIT(A) where appeal of the assessee was dismissed sustaining the order of the AO. 4. Aggrieved, assessee has, inter alia, challenged the validity of 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.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 dated 21.07.2022 was issued. In response, the assessee again filed its return declaring total income of ₹1,32,63,010, which was accepted as returned income. However, while completing the reassessment, the Assessing Officer proceeded to make further additions and assessed ₹4

KROSS LIMITED,ADITYAPUR vs. DCIT,CIRCLE-1, JAMSHEDPUR

Accordingly, ITA No. 98/RAN/2025 is allowed

Bench: the CIT(A) where appeal was dismissed on wrong facts.4. Dissatisfied with the above order, assessee is in appeal before this Tribunal.

reassessment under Section 147 r.w.s. 144B of the Act on 30.03.2022, determining total income at ₹4,91,63,670/-, after

KROSS LIMITED,ADITYAPUR vs. DCIT, CIRCLE-1, JAMSHEDPUR

Accordingly, ITA No. 98/RAN/2025 is allowed

Bench: the CIT(A) where appeal was dismissed on wrong facts.4. Dissatisfied with the above order, assessee is in appeal before this Tribunal.

reassessment under Section 147 r.w.s. 144B of the Act on 30.03.2022, determining total income at ₹4,91,63,670/-, after

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

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

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

ANWESH KUMAR CHAKRABORTY,KOLKATA vs. ASSESSING OFFICER, JAMSHEDPUR

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes only

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay(Virtual Hearing) Anwesh Kumar Chakraborty, Assessing Officer, Flat No. 04, Ashabori Apartment, 11/1 Jamshedpur. Vs. Kolupara Lane, Dhakuria, Kolkata-700031 (West Bengal) Pan No. Aiqpc 6936 M Appellant/ Assessee Respondent/ Revenue

Sections 148 to 153, assessee or reassess such income. But in this case, there has been no income which has escaped assessment, the assessing officer in regard to deductions claimed by assessee wanted documentary evidences for the same. 2. The learned CIT(A) is not justified by upholding the AO's order of addition

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

reassessment order passed by AO under Ld. PCIT’s direction. Therefore, the assessee contended that there was due application of mind by the AO in the original assessment order and the revision under section 263 was unjustified. 4

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

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

reassessment proceedings, the assessee furnished all primary evidences, including loan confirmations, ledger accounts, PAN and CIN details of the lenders, bank statements showing the loan entries, and their audited balance sheets as on 31.03.2015. These documents formed part of the assessee’s audited financial statements. Thus, the assessee discharged the primary onus cast upon it under section

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

section 263 of the Income-tax Act, 1961 (“the Act”) dated 31.03.2025 for A.Y. 2018–19. The assessee challenges the legality and validity of the assumption of jurisdiction by the PCIT and 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

LUXMI HARD COKE MFG. CO,,DHANBAD vs. ITO WARD-1(1), DHANBAD

In the result, both appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhury

Section 147/148 of the Act. Thus, legal ground is answered in favour of assessee. Luxmi Hard Coke Mfg. Co. Vs ITO Accordingly the reassessment order is declared bad in law and void ab-initio and all the subsequent proceedings thereafter, therefore, becomes nonest. Since this legal ground has been answered in favour of assessee, therefore, all other grounds of appeal

LAXMI HARD COKE MFG CO.,DHANBAD vs. ITO WARD 1(1), DHANBAD

In the result, both appeals of the assessee are allowed

Bench: Shri Partha Sarathi Chaudhury

Section 147/148 of the Act. Thus, legal ground is answered in favour of assessee. Luxmi Hard Coke Mfg. Co. Vs ITO Accordingly the reassessment order is declared bad in law and void ab-initio and all the subsequent proceedings thereafter, therefore, becomes nonest. Since this legal ground has been answered in favour of assessee, therefore, all other grounds of appeal