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

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

reassessment order nor in the penalty order there is any positive finding establishing that the assessee during the course of search found to be owner of any money, bullion, jewellery or other valuable article or thing, therefore, the penalty by invoking Explanation 5 to Section

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

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

reassessment order nor in the penalty order there is any positive finding establishing that the assessee during the course of search found to be owner of any money, bullion, jewellery or other valuable article or thing, therefore, the penalty by invoking Explanation 5 to Section

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Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions.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 order on technical grounds. The learned Departmental Representative supported the assessment order and submitted that issuance of notice under section 143(2) of the Act in one of the proceedings is sufficient compliance. 5

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)

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 the matter to the Departmental Valuation Officer (DVO), rendering the assessment invalid. 5

KROSS LIMITED,JAMSHEDPUR vs. PCIT, RANCHI, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

section 263 of the Act is 5 AY: 2012-13 Kross Limited barred by limitation or not. In our considered opinion ,the scope of powers of the AO in original assessment proceedings and reassessment

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)

reassessment proceedings on the ground that the approval obtained under section 151 of the Act for issuance of notice under section 148 of the Act was granted in a mechanical manner without application of mind. The Ld. AR submitted the copy of the approval order supplied to the assessee shows that approval was granted commonly for multiple assessees through

MAYUR RICE MILLS PRIVATE LIMITED,JHUMRITELAIYA vs. PCIT, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Rajesh Kumar, Hon’Bleassessment Year: 2012-13 Mayur Rice Mills Private Limited Pr. Cit, Ranchi Gujhandi Road Vs Vill – Barwadih, Jhumritelaiya Pin - 825409 Pan : Aafcm5928H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.K. Pransukha, A/R Revenue By : Shri Sanjay Mukherjee, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 21/09/2022 घोषणा क" तारीख /Date Of Pronouncement : 02/11/2022 आदेश/O R D E R Per Shri Rajesh Kumar: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax (Appeals) - Ranchi (Hereinafter ‘Ld. Pr. Cit’), Dated 30/03/2022, Passed Under Section 263 Of The Income Tax Act, 1961 (In Short “The Act”), For Assessment Year 2012-13. 2. The Sole Issue Raised In The Various Grounds Of Appeal Is Against The Invalid Exercise Of Jurisdiction U/S 263 Of The Act By The Ld. Pr. Cit As The Revisionary Proceedings Are Hopelessly Barred By Limitation.

5. The ld. Counsel for the assessee contended before us that the revisionary jurisdiction exercised by the ld. Pr. CIT is incorrect and hopelessly barred by limitation. The ld. Counsel for the assessee drew out attention to the provisions of Section 263(2) of the Act which provides for limitation for exercise of jurisdiction

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

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

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)

sections 148 to 153 , assess or reassess such income and also any other income chargeable to tax 5 which has escaped

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.

5,09,17,506/- vide order dated 17.12.2018 passed under Section 147 read with 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

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

reassessment proceedings under Section 153A of the Act of 1961. That was not done within the period of limitation prescribed under Section 153B of the Act of 1961. The respondent-authority was fully aware of the fact that proceedings under Section 153C of the Act of 1961 would be barred by limitation, therefore, recourse was taken to the provisions contained

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

reassessment proceedings under Section 153A of the Act of 1961. That was not done within the period of limitation prescribed under Section 153B of the Act of 1961. The respondent-authority was fully aware of the fact that proceedings under Section 153C of the Act of 1961 would be barred by limitation, therefore, recourse was taken to the provisions contained

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”).

reassessment order making additions over and above the returned income is bad in law. Besides that the interest income of ₹4,75,23,253 arose from fixed deposits maintained as security with I.T.A. No.468/Ran/2025 Misrilall Jain & Sons Government departments such as Forest Department, Pollution Control Board and mining authorities for obtaining and renewing mining licences and contracts. No fresh deposits

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 making an addition of ₹2,00,00,000/- crore treating the pending share application money as unexplained under Section 68 of the Act. 3. Aggrieved by the order of Ld. AO assessee went in appeal before the CIT(A) where

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 making an addition of ₹2,00,00,000/- crore treating the pending share application money as unexplained under Section 68 of the Act. 3. Aggrieved by the order of Ld. AO assessee went in appeal before the CIT(A) where

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

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