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:

30,000, Premium ₹5,20,000 (1,300 shares) Ishan Tie -Up Pvt. Ltd. – Share capital ₹4,00,000, Premium ₹16,00,000 (4,000 shares) Linton consultant Pvt. Ltd. – Share capital ₹2,00,000, Premium ₹8,00,000 (2,000 shares) The AO issued notices under sections 142(1) and 133(6) to the subscribers. Two notices were

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:

2] [In favour of assessee] ii. PCIT Panji Vs Paradise Inland Shipping Pvt Ltd – (2018) 93 Taxman 84 (SC) SLP Dismissed - S. 68 Bogus share capital: Companies which invest share capital cannot be treated as bogus if they are registered and have been assessed. Once the assessee has produced documentary evidence to establish the existence of such companies, the burden

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

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

2,00,000/- in the name of M/s Auto Car and the part liability of Rs.12,931/- in the name of M/s Balaji Batteries Storage have ceased / remitted. Therefore, addition to the extent of Rs.2,12,931/- i hereby confirmed u/s 41(1) of the I.T. Act and remaining addition of Rs.3,61,98,164/- is hereby deleted

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

Bench: Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

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

Bench: Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

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

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (Α.Υ :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement Per Bench : आदेश / Order These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

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

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M Vs. Acit, Circle-1, Dhanbad & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / Order Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Id.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011- 12 & 2012-13, Respectively. The Assessee Has Also Filed Cross Objections Arising Out Of Appeals Of Revenue For A.Y.2009-2010 & 2011-2012. 2. First, We Shall Take Up The Appeals Of The Revenue Filed For A.Y.2009- 2010 & 2011-2012. Ld. Ar, At The Outset, Filed A Chart Specifying The Issues Involved In The Appeals Of The Revenue, Which Reads As Follows :- Bharat Coking Coal Limited, Dhanbad Pan: Aaacb7934M Additions Disputed In Appeal Before Hon'Ble Itat - By It Department Si No.

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

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

In the result, both appeals of revenue and the cross objections of the assessee are dismissed and appeals of assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.291,293,294/Ran/2017 (A.Y :2009-10, 2011-12 & 2012-13) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Aaacb 7934 M & आयकर अपील सं./Ita Nos.300 & 302/Ran/2017 (A.Y :2009-10 & 2011-12) Acit, Circle-1, Dhanbad Vs. M/S Bharat Coking Coal Ltd, Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M & Cross Objection Nos.09 & 11/Ran/2018 (Arising Out Of Ita Nos.300&302/Ran/2017) (A.Y :2009-10 & 2011-12) M/S Bharat Coking Coal Ltd, Vs. Acit, Circle-1, Dhanbad Finance Directorate, Koyla Bhawan, Koyla Nagar, P.O.Bccl, Township, Dhanbad-826005 स्थायी लेखा सं./Pan No. : Acb 7934 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri M.K.Chowdhary & Shri Devesh Poddar, Advocates राजस्व की ओर से /Revenue By : Shri Rajib Jain, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख/Date Of Pronouncement : 06/01/2026 आदेश / O R D E R Per Bench : These Are The Cross Appeals Filed By The Assessee & Revenue Against The Separate Orders Passed By The Ld.Cit(A), Ranchi/Nfac, Delhi, Dated 20.09.2017 & 19.09.2017 For The Assessment Years 2009-10, 2011-

Section 14A of the Act r.w. Rule 8D of the Rules were applicable on the assessee and after giving a show cause computed the disallowance at Rs. 27,19,753/- comprising of Rs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule 8D(2)(iii) of the Rules

KANTA DEVI SARAWGI,GIRIDIH vs. ACIT, C.C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

HARISH KUMAR SARAWGI,GIRIDIH vs. ACIT, C.C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

SUNILA DEVI SARAWGI,GIRIDIH vs. ACIT, C. C. , DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

SAMIR KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

SANGITA DEVI SARAWGI,GIRIDIH vs. ACIT, C.C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

AAKRITI SARAWGI,,GIRIDIH vs. ACIT CENTRAL CIRCLE, DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

RAJESH BADRI PD. MODI,GIRIDIH vs. ACIT, CENTRAL CIRCLE, DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

MANJU DEVI SARAWGI,GIRIDIH vs. ACIT, CENTRAL CIRCLE, DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

PARAS KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

SANTOSH KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 to 69D of the Act. Consequently, the Assessing Officer invoked the provisions of section 115BBE of the Act and applied the special rates of tax by treating it as undisclosed income. The Ld. AR has also filed a written submission as under: "1. That a search action U/s 132 was conducted upon the Atibir Group on 17/03/2021

DCIT CIRCLE-1 , RANCHI vs. CCL LTD , RANCHI

In the result, appeal of the assessee in ITA No

30,88,83,502 1 2 Land & Crop Compensation 24,09,000 7,00,000 5,00,000 34,14,00,000 12,00,000 1,00,000 3 Credit of Dividend Distribution Tax 4 Rehabilitation fund Contribution Expenses 5 IICM Charges 2,37,61,000 2,40,00,000 2,40,00,000 2