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

1 Prior period 91,73,000/- Whether ascertained & expenses crystalized during the year. 2 Land & Crop 26,65,86,000/- Whether of enduring Compensation nature i.e. Capital or of revenue nature. 3. Provisions for 125,10,67,000/- Whether ascertained Executive Salary during the year. However, revision allowed during A.Y. 2010- 11 (para "h" above) Total Rs. 152,68

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

1 Prior period 91,73,000/- Whether ascertained & expenses crystalized during the year. 2 Land & Crop 26,65,86,000/- Whether of enduring Compensation nature i.e. Capital or of revenue nature. 3. Provisions for 125,10,67,000/- Whether ascertained Executive Salary during the year. However, revision allowed during A.Y. 2010- 11 (para "h" above) Total Rs. 152,68

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

68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (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

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

68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (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

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

11, is being considered first. The facts of the present case, in brief, are that the appellant company is a Government of India Enterprise and one of the five subsidiaries of Coal India Ltd. The assessment under Section 143(3) of the Income Tax Act, 1961 (in short, the Act) was passed by the Assessing Officer and following additions/disallowances

M/S MANIKARAN POWER LTD,RANCHI vs. ACIT, CIRCLE-2, RANCHI

In the result, the appeal of the assessee in ITA No

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 01/Ran/2025 (Assessment Year: 2022-23) A.C.I.T., Manikaran Power Limited, Central Circle-2, Manikaran Tower, Kilburn Colony, Vs. Ranchi. P.O. Hinoo, Ranchi-834002 (Jharkhand) J.C.I.T. (In Situ), Pan No. Aaecm 4555 F Ranchi. Revenue/ Appellant Respondent/ Assessee Manikaran Power Limited, A.C.I.T., Manikaran Tower, Kilburn Colony, Central Circle-2, Vs. P.O. Hinoo, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Aaecm 4555 F Revenue/ Appellant Respondent/ Assessee

1) or Section 68 of the Act, as we have already deleted the addition itself in assessee's appeal, this ground no more survives. Consequently, the appeal of the revenue stands dismissed. 11

ACIT, CENTRAL CIRCLE-1,, RANCHI vs. SHRI KAMAL BHUSHAN, RANCHI

In the result, the appeals of the revenue and the cross-objections of the assessee are dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma] I.T.(Ss)A. No. 1/Ran/2021 I.T.(Ss)A. No. 5/Ran/2019

section 68 which has been cross checked with the details submitted in the paper book and as such. It is also observed that the assessing officer at time of assessment has failed to look into the submissions of the appellant and for that matter give any categorical finding for making the addition as from the order of assessment

ACIT,CIRCLE-2(1), HAZARIBAG vs. SANJAY KUMAR UPADHYAY, HAZARIBAG

In the result, the appeal filed by the Revenue is dismissed

Bench: Sri Sanjay Garg & Dr. Manish Borad

11. Ground no. 3 raised by the Revenue relates to addition of Rs. 46,86,305/- made by ld. AO invoking the provisions of Section 68 of the Act. Brief facts relating to the issue are that there was an increase in the capital during the year at Rs. 46,86,305/-. The claim of the assessee was that

M/S ANJENEYE ISPAT LTD.,SARAIKELA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.74/Ran/2022 Assessment Year: 2008-09 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand – 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur……....….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 11, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Ld. Cit(A)”) Dated 21.08.2018 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 Company Is Engaged In The Manufacturing Of Pig Iron. It Filed Its Return Of Income Declaring Total Income Of ₹1,41,05,250, Which Was Processed Under Section 143(1). During The Assessment Proceedings, The Assessing Officer Noticed That The Assessee Had Received Share Capital & Share Premium Aggregating To ₹3,00,00,000 During The Relevant Previous Year. The Assessing Officer Issued Notices Under Sections 142(1) & 148 Requiring The Assessee To Furnish Complete Details Of The Share Applicants, Including Identity, Creditworthiness & Genuineness Of The Transactions. In Response, The Assessee Furnished Complete Details In Respect Of The Share Capital/Share Premium Received From The Following Parties:

11, 2025 Date of pronouncing the order : January 06, 2026 ORDER Per Sonjoy Sarma, Judicial Member: This appeal filed by the assessee is directed against the order of the CIT(A), Jamshedpur (hereinafter referred to as “ld. CIT(A)”) dated 21.08.2018 passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”). 2. Brief

ADHUNIK AKSHAT UDYOG PVT. LTD.,,DUMKA vs. ACIT, CIRCLE-3(1), DEOGHAR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.163/Ran/2025 Assessment Year: 2012-13 Adhunik Akshat Udyog Pvt. Ltd……………............................……….……Appellant Industrial Area, Babupur, Muffasil Thana Dumka, Jharkhand – 814101. [Pan: Aabca4896Q] Vs. Acit, Circle-3(1), Deoghar…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri Sushil Pransukha, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 28, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 11.03.2025 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2012–13. 2. Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For Ay 2012–13 Declaring Total Income Of ₹2,57,551. The Case Was Reopened Under Section 147 On The Ground That The Assessee Had Raised Share Capital & Share Premium From Certain Entities, Whose Financial Capacity & Genuineness Of Investment Remained Unexplained. During Assessment, The Ao Noted That The Assessee Had Introduced Share Capital Of ₹37,50,000 From The Following Four Private Limited Companies:

11, the relevant year for examination, if any, would have been AY 2011–12, not AY 2012–13. The AO erred in invoking section 68 of the Act in the present year. The ITAT Kolkata in Pujita Merchandise Pvt. Ltd. (supra) has held in identical circumstances that addition under section 68 is unsustainable when no fresh share application

JOKHIRAM DURGADUTT,RANCHI vs. DCIT, CIRCLE-1, RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayjokhiram Durgadutt, D.C.I.T., 9, J.D. Corporate, Behind J.D. High Circle-1, Vs. Street, Main Road, Ranchi-834001 Ranchi. (Jharkhand) Pan No. Aabfj 2200 Q Appellant/ Assessee Respondent/ Revenue

section 271 (1)(c)." 4. The contention of the Ld. Commissioner of Income Tax ( Appeal ) that the assessee had claimed an unallowable standard deduction of Rs. 68,36,208/- is fully compensated by way of depreciation being allowed Rs. 2,31,19,350/-. So, the revenue is no way being put at loss or in other wards the assessee

ITO, TDS,, RANCHI vs. M/S. CHINNAMASTIKA CEMENT & ISPAT LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

1,98,81,783.00 2014-15 7,89,22,334.00 5,13,02,422.00 2,76,19,912.00 2015-16 16,65,16,961.00 11,73,87,499.00 4,91,29,462.00 2016-17 29,71,64,279.00 23,13,95,671.00 6,57,68

ITO, TDS, RANCHI, RANCHI vs. M/S. CHHINAMASTIKA CEMENT & ISPAT PVT. LTD.,, RAMGARH

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

1,98,81,783.00 2014-15 7,89,22,334.00 5,13,02,422.00 2,76,19,912.00 2015-16 16,65,16,961.00 11,73,87,499.00 4,91,29,462.00 2016-17 29,71,64,279.00 23,13,95,671.00 6,57,68

RAJESH JALAN,DHANBAD vs. DCIT/ACIT, CIRCLE-1, DHANBAD

The appeal of the assessee is allowed in full

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

11. Accordingly, the addition of ₹20,86,500/-as made under Section 69A of the Act is hereby directed to be deleted. 12. In view of the above discussion the addition of ₹7,40,000/- under Section 68 of the Act and the addition of ₹20,86,500/- made under Section 69A of the Act are deleted

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

11. On this issue, the Id. AR submitted that the assessee had received the said loans in the ordinary course of business, duly recorded them in the books of accounts, and had repaid the same during the year itself. The assessee had also deducted TDS on the interest paid under section 194A of the Act and deposited

PADAM KUMAE JAIN,RANCHI vs. CIT, CENTRAL, PATNA

In the result, the appeal filed by the assessee is allowed

Bench: Shri S.S. Godara, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./Ita No.289/Ran/2019 (िनधा"रणवष" / Assessment Year: 2012-13) Padam Kumar Jain Vs. Cit, Central, Cr Building, Beer Chand Patel Marg, Patna – 800001. Ratanlalsurajmal Compound, Main Road, Ranchi – 834001, Jharkhand "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abrpj 0001 E (Assessee) .. (Revenue)

section 142(1) of the Act, dated 20.06.2016, which were furnished by the assessee during the original assessment proceedings, the copy of notice u/s 142(1) of the Act is reproduced below for ready reference: “Sub: Income Tax assessment in your case AY 2012-13 notice u/s 142(1) reg. Following details / explanations / clarifications may be furnished

CCL,RANCHI vs. DCIT CIR-1, RANCHI

11,00,000\n68,41,00,000 63,00,00,000\n11 Provision for NCWA\n2,89,76,00,000\n12 Executive Pay Rivision\n12,86,00,000\n1,36,26,00,000\n13 Siding Maintenance Expenses\n22,87,00,000\n21,00,000\n23,22,00,000\n10,68,00,000\n14 Miscellaneous Expenses

DCIT CIR-1 , RANCHI vs. M/S CENTRAL COALFIELDS LTD, RANCHI

11,00,000\n68,41,00,000\n63,00,00,000\n11 Provision for NCWA\n2,89,76,00,000\n12 Executive Pay Rivision\n12,86,00,000\n1,36,26,00,000\n13 Siding Maintenance Expenses\n22,87,00,000\n21,00,000\n23,22,00,000\n10,68,00,000\n14 Miscellaneous Expenses