M/S CHHAGANLAL AGARWAL,CHAIBASA vs. ITO,WARD-3(4), CHAIBASA

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.319/Ran/2018 (नििाारण वषा / Assessment Year :2010-2011) M/S Chhaganlal Agarwal, Vs. Ito Ward-3(4), Chaibasa Bari Bazar, Chaibasa-833201 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aaffc 6053 J (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

40(b))(v) was applicable, as such, 2 disallowance made on the basis of provision applicable upto to A.Y'. 2009-10 is unjustified, illegal and incorrect. 4. For that Ld. A.O. was not justified in charging interest u/s 234A and 234B on the assessed income. Interest should be charged on the returned income following the decision of Hon'ble Jharkhand

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

reassessment proceedings initiated u/s. 148 of the Act and the order passed u/s. 147 read with section 143(3) of the Act, assessee has prayed that the legal ground goes to the root of the matter for which all the facts are already on record and it may be admitted for adjudication. Ld. Counsel placed reliance on the decision

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

40,62,030, indicating a discrepancy of ₹30,18,000, which was not explained. Based on the above, Ld. PCIT invoked powers under Section 263 of the act, set aside the assessment order, and directed a fresh assessment after proper verification. 3. Dissatisfied with the above order, assessee is in appeal before this tribunal. At the time of hearing

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

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

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 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

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 the impugned penalty order imposed a penalty

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\nis dismissed

40,000/-\nTotal Additions/Disallowances\n* 97,77,17,000/-\nThe penalty proceedings under Section 271(1)(c) of the Act were separately\ninitiated with the issue of notice under Section 274 read with section 271(1)(c)\nof the Act and finally, the Assessing Officer vide the impugned penalty order\nimposed a penalty

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”).

40,80,800. The case was selected for scrutiny, and the assessment was completed under section 143(3) of the Income-tax Act, 1961, vide order dated 15.12.2016, accepting the returned income. Subsequently, the Assessing Officer issued a notice under section 148 of I.T.A. No.180/Ran/2025 the Act dated 22.11.2019, i.e., after the expiry of four years from

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.

40,000/- being the amount of cash withdrawn from the bank account. Complete details for the same was furnished before the authorities below who failed to consider the same and give credit for the same against the addition being made for large cash deposit. 4. For that Ld. CIT(A) was not justified in confirming the addition

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

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 under Section 274 read with section 271(1)(c) of the Act and finally

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

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 under Section 274 read with section 271(1)(c) of the Act and finally

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

40(a)(ia) in respect of IICM Charges. The expenses were treated as capital expenses by the Assessing Officer. The CIT(A) NFAC too has dismissed the assessee's appeal on the same ground in respect of IICM expenses in A.Y. 2008-09. The assessee had claimed the same expenses and again after being disallowed by the Assessing Officer, establishing

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

40(a)(ia) in respect of IICM Charges. The expenses were treated as capital expenses by the Assessing Officer. The CIT(A) NFAC too has dismissed the assessee's appeal on the same ground in respect of IICM expenses in A.Y. 2008-09. The assessee had claimed the same expenses and again after being disallowed by the Assessing Officer, establishing

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

40(a)(ia) particulars. However, deleted on merits of 271(1) (c) by Ld. CIT(A) for the A.Y. 2009-10 to A.Y. 2013-14 4. Provisions 213,49,00,000/- Was not ascertained. Towards NCWA However,, in AT 2017-18 VIII quantum deleted by the Ld. CIT(A) under similar vide his order dated 21/12/2023 in appeal

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

40(a)(ia) in respect of IICM Charges. The expenses were treated as Capital expenses by the Assessing Officer. The CIT(A) NFAC too has dismissed the Assessee's appeal on the same ground in respect of IICM expenses in A.Y. 2008-09. The Assessee had claimed the same expenses again and again after being disallowed by the Assessing Officer

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

40(a)(ia) in respect of IICM Charges. The expenses were treated as Capital expenses by the Assessing Officer. The CIT(A) NFAC too has dismissed the Assessee's appeal on the same ground in respect of IICM expenses in A.Y. 2008-09. The Assessee had claimed the same expenses again and again after being disallowed by the Assessing Officer