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:

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 and share premium from certain entities, whose financial capacity and genuineness of investment remained unexplained. During assessment, the AO noted that the assessee had introduced share capital of ₹37,50,000 from the following

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)

8. Addition under Section 69A of the Act ₹20,86,500/- (Introduction of Capital) The Assessing Officer further noted that the assessee had introduced total capital of ₹27,02,500/- in his proprietary business during the year, of which ₹6,16,000/- was through bank and the balance ₹20,86,500/- was claimed to be out of cash

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

8 of 10 I.T.A. No.: 94/Ran/2019 Assessment Year: 2015-16 Sanjay Kumar Upadhyay. (ii) The AR has also brought out the legal provisions of section 68 of the Income-tax Act, 1961, decision of the Hon’ble SC on interpretation of statutes as well as various other court decisions establishing that the amount involved is not covered under

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.

13. No fresh share application money was received during the assessment year 2013–14. Hence, the basic condition for invoking section 68 of the Act i.e., receipt of a credit during the relevant previous year is not satisfied. 8

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.

13. No fresh share application money was received during the assessment year 2013–14. Hence, the basic condition for invoking section 68 of the Act i.e., receipt of a credit during the relevant previous year is not satisfied. 8

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

8. On the other hand, the learned AR submitted that the AO was not justified in making the addition of ₹3,29,200 on a mere presumption that the assessee must have paid commission at 2% on the trading profit of ₹1,64,60,100. It was argued that the assessee had already paid STT and I.T.A. No.436/Ran/2024 Benko Traders

ACIT, CIRCLE-3, RANCHI vs. SHRI SUMIT RAMSISARIA, RANCHI

Bench: Shri J.Sudhakar Reddy & Shri S.S.Godara

13. We have heard the rival parties and perused the materials available on record. From the aforesaid discussion we find that the addition was confirmed by the AO on account of non-service of notice issued under section 133(6) of the Act for the purpose of the confirmation of sundry creditors. However we find that

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)

68,190/- plus Rs.1,05,28,110/-) at the time of assessment without considering supportive evidences thereof, which indicates that the admissibility of the expenditure during the year was not properly examined. As per the submission, the assessee has contended that during the assessment proceedings, the confirmation of M/s. Core Minerals and M/s. Rajat Minerals along with the relevant materials

SANJEEV SABLOK,JAMSHEDPUR vs. ITO WD-1(4), JSR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.147/Ran/2018 (नििाारण वषा / Assessment Year :2010-2011) Sanjeev Sablok, Vs. Ito, Ward-1(4), 4, I.C.Road, Circuit House Area Jamshedpur Bistupur, Jamshedpur-831001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Adkps 4050 M (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri M.K.Choudhary, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

8 Interest of capital from parthership firm Rs.1,09,130.00 Partners’ remuneration from partnership firm Rs. 75,686.50 Net profit from Sablok & Associates Rs.3,81,047.33 Total income under the head income from business has been declared Rs.5,65,863.83 Further, we notice that if the assessee has offered income u/s.44AD of the Act, he should separately shown

SALUJA STEEL AND POWER PVT. LTD.,,GIRIDIH vs. ACIT, C, C., DHANBAD

In the result, appeal of the assessee is allowed

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

8. It was the submission that the said Ganeev Associates has been categorically shown as shareholders holding more than 5% share holding in the company. It was the submission that clearly the reason recorded are without any basis and is unsupported by any factual connection with the assessee. 9. Ld.AR further drew our attention to the alleged income escaping assessment

SRI KAMLESH KUMAR SINGH,DALTONGANJ vs. ACIT,CIR-1, RANCHI

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No. 49/Ran/2017 Assessment Year: 2009-2010 Smt. Madhu Singh,...................................Appellant Hamidganj, Daltonganj-822101 [Pan: Bbjps0426B] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Circle-1, Ranchi & I.T.A. Nos. 53 & 54/Ran/2017 Assessment Years: 2008-2009 & 2009-2010 Shri Kamlesh Kumar Singh,...................Appellant Hamidganj, Daltonganj-822101 [Pan: Afzps8288J] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Circle-1, Ranchi Appearances By: Shri Devesh Poddar, Advocate, Appeared On Behalf Of The Assessee Shri P.K. Koley, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : May 22, 2023 Date Of Pronouncing The Order : August 7Th, 2023 1 Assessment Year: 2009-2010 Smt. Madhu Singh & Ita Nos. 53 & 54/Ran/2017 Assessment Years: 2008-2009 & 2009-2010 Shri Kamlesh Kr. Singh

8 Assessment Year: 2009-2010 Smt. Madhu Singh & ITA Nos. 53 & 54/RAN/2017 Assessment Years: 2008-2009 & 2009-2010 Shri Kamlesh Kr. Singh we are inclined to hold that the finding of ld. CIT(Appeals) of confirming substantive basis in the hands of assessee’s husband is uncalled for. Since the assessee has explained the source of the said

ITO WD -2(1), JAMSHEDPUR vs. M/S OM DAYAL INGOTS &STEEL CO. PVT LTD , JAMSHEDPUR

In the result, application u/s 27 filed by the assessee is allowed and both the appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

8. Having heard the rival contentions and perusing the material on record including the provisions of section 151 of the Act, we note that it is amply clear from the above that the approval has to be taken form PCIT where notice is to be issued beyond the period of four year from the end of assessment year. However

ITO WARD-2(1), JAMSHEDPUR vs. M/S OM DAYAL INGOTS&STEEL CO. PVT LTD , JAMSHEDPUR

In the result, application u/s 27 filed by the assessee is allowed and both the appeals of the revenue are dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

8. Having heard the rival contentions and perusing the material on record including the provisions of section 151 of the Act, we note that it is amply clear from the above that the approval has to be taken form PCIT where notice is to be issued beyond the period of four year from the end of assessment year. However

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

13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce

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

13,95,671.00 6,57,68,608.00 2017-18 6,84,08,367.00 4,24,21,613.00 2,59,86,754.00 Shri Dinesh Kumar Choudhary stated that while making payments to various transporters, no TDS has been deducted barring a few entity as these transporters were having less than ten vehicles/carriers, however, Shri Dinesh Kumar Choudhary could not produce

CCL,RANCHI vs. DCIT CIR01 , RANCHI

8 of its order has held as follows:-\n8.\nIt is undisputed that the assessee acquired a mining lease of 9.99\nkilometers situated in village-Chittorgarh for obtaining lime stone\nused as raw material for manufacture of cement. To carry out the\nmining operation/business activity, the assessee has paid the\namount in question to land owners for damage caused

ACIT, CENTRALC CIRCLE-1, RANCHI, RANCHI vs. IMPERIAL AUTOMOBILES PRIVATE LIMITED, KOLKATA

In the result, appeal of the revenue stands dismissed

Bench: BEFORES/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY (Accountant Member)

13. P a g e 1 | 8 Assessment Year : 2012-13 2. Smt. Rinku Singh, Ld CIT DR appeared for the revenue and Shri R.R.Mittal, ld AR appeared for the assessee. 3. It was submitted by ld AR that the impugned assessment year is 2012-13 and the original assessment order came to be passed u/s.143

TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

13,17,25,335/- and consequently, made an adjustment in respect of the short fall. The ld. AR drew our attention of the various clauses of the agreement which were shown from pages 198 of the paper book. He further drew our attention to the reply filed by the assessee to the DRP at page

M/S BHARAT COOKING COAL LTD ,DHANBAD vs. ACIT CIR-1 , DHANBAD

8 years for carry forward and set off of unabsorbed\ndepreciation had been dispensed with, the unabsorbed\ndepreciation from A.Y. 1997-98 upto the A.Y. 2001-02 got\ncarried forward to the assessment year 2002-03 and became\npart thereof, it came to be governed by the provisions of section\n32(2) as amended by Finance