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

147. He pointed out that Ld. AO had issued first notice u/s. 142(1) on 12.07.2017, then on 14.08.2017. Again on 17.11.2017 Ld. AO issued a letter and thereafter on 13.12.2017, Ld. Counsel further submitted that in the notice issued by the Ld. AO u/s. 142(1), it was mentioned that in case of non-compliance, assessment will

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.

10. Replying to above, ld. DR submitted that the AO proceeded to invoke provision of Section 147 & 148 of the Act on verification of bank statements of State Bank of India, therefore, initiation of reassessment proceedings are quite correct and valid. He also submitted that the second issue is pertaining to deemed rental income from house property at Jamalpur, which

SMT. WARSHA BAGARIA,RANCHI vs. ITO,WARD-3(3), RANCHI

In the result, appeal of the assessee is allowed on legal ground

147 stating that assessee received Rs. 4,08,205/- from M/s Escort Finance Ltd. on which TDS was deducted and same escaped assessment. Ld. AO while completing the assessment U/s 147/143(3) made a addition of Rs. 12,07,879/- stating that this entire amount was received by assessee during the year from M/s Escort Finance which included

SHAH BROTHERS,CHAIBASA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, Revenue's appeal stands allowed partly for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.275/Ran/2023 Assessment Year: 2016-17 Shah Brothers, Chaibasa……...................…...........................……….……Appellant Sadar Bazar, West Singhbhum, Jharkhand-833201. [Pan: Aazfs7498F] Vs. Acit, Central Circle-1, Ranchi..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar & R. R. Mittal, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2025 Date Of Pronouncing The Order : July 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 28.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income U/S 139 Of The Act Declaring Total Income Of Rs.14,04,03,980/- For Assessment Year 2016-17. The Assessment Of The Assessee Was Completed U/S 143(3) Of The Act On 31.102.108 Accepting The Said Returned Income. Subsequently, Based On Information Received From Dcit, Cc-1(3), Mumbai, It Was Alleged That The Said Assessee Had Claimed A Bogus Contract Expenses Of Rs.2,69,14,526/- In Lieu Of The Bogus Work Order To M/S Pandhe Infracons Pvt. Ltd. During The F.Y 2015-16 Without Any Actual Work Had Been Performed. The Revenue Relied Upon Search Operation U/S 132 Of The Act Conducted On M/S

147 of the Act were initiated and notice u/s 148 was issued to the assessee and the assessee filed reply in response to the said notice. However, the Assessing Officer disallowed the said amount of Rs.2,69,14,526/- with a view that the same was a bogus transaction. 3. Dissatisfied with the above order, the assessee preferred an appeal