DR MABLE KATYARE ,HAZARIBAGH vs. ITO WARD-1(1), HAZARIBAGH

Appeals are allowed

Bench: Shri S.S, Godaraassessment Year:2013-14 बनाम / Dr. Mable Katyare, H’Bagh Income Tax Officer, Pan: Afspk1459G Ward-1(1), H’Bagh V/S. अपीलाथ" /Appellant ""यथ" /Respondent .. अपीलाथ" क" ओर से/By Appellant Shri Devesh Poddar, Advocate ""यथ" क" ओर से/By Respondent Shri Chandan Das, Jcit-Dr सुनवाई क" तार"ख/Date Of Hearing 10-01-2019 घोषणा क" तार"ख/Date Of Pronouncement -04-2019 Assessment Year:2013-14 बनाम / Ramchandra Prasad Income Tax Officer, Pan: Afopp7929L Ward-1(1), H’Bagh V/S. अपीलाथ" /Appellant ""यथ" /Respondent .. अपीलाथ" क" ओर से/By Appellant Shri Devesh Poddar, Advocate ""यथ" क" ओर से/By Respondent Shri Chandan Das, Jcit-Dr सुनवाई क" तार"ख/Date Of Hearing 09-01-2019 घोषणा क" तार"ख/Date Of Pronouncement 8-04-2019

reassessment proceedings u/s 147 of the Act on the basis of information received based on material qua the assessee, found in the search on the Santosh Group of Institutions, Ghaziabad. ITA Nos.287 & 336/Ran/2017 Dr. Mable Katyare & Ramchandra Prasad Page 4 9. The proposition canvassed by the assessee is that as per the provisions of section 153C

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)

12,65,350. Subsequently, the assessment was reopened by issuance of notice received unsecured loans amounting to ₹30,00,000, the genuineness of which was doubted. In response to the notice, the assessee complied with the proceedings and the assessment was completed under section 147 read with section 143(3) of the Act determining total income

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.

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 on the ground that the notice under Section 148 dated

SRI AJAY KUMAR MURARKA,JAMSHEDPUR vs. ACIT, JAMSHEDPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal

reassessment proceeding u/s. 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

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

reassessment proceeding u/s. 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

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

12, 2025 Date of pronouncing the order : November 19, 2025 ORDER Per Sonjoy Sarma, Judicial Member: 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

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.

12. On careful consideration of above rival submission, first of all, I may point out that the AO on 21.09.2017 recorded the following reasons for initiation of reassessment proceedings u/s.147 of the Act and issuance of notice u/s.148 of the Act :- “21.09.2017 On verification of the case record for the A.Y. 2012-13, the following facts have been noticed

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

147 determining the total income at ₹2,26,89,300. 3. Aggrieved, the assessee preferred an appeal before the CIT(A), who deleted the additions observing as under: “Appellate findings: I have heard the rival submissions and perused the orders of the Ld.AO and the material available on record. In his written submission the Ld. AR stated that

ROSHAN MAHESHWARI,JAMSHEDPUR vs. ITO,WARD-3(5), CHAIBASA

In the result, appeals filed by the assessee are allowed

Bench: S/Shri Chandra Mohan Garg & Laxmi Prasad Sahu

u/s. 234A and 234B, on the tax payable on the returned income, instead of tax payable on the returned income is unjustified. 9. For that, order grounds if any, would be urged at the time of hearing.’ 3. At the time of hearing, ld A.R. argued the legal issue that the assessment years involved in this case

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