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:

21, Kolkata vs. Pujita Merchandise Pvt. Ltd. [ITA No. 1293/Kol/2024, order dated 06.11.2024, wherein it was held that where share application money was received in earlier years and only shares were allotted in the relevant year, no addition under section 68 of the Act could be made in the current year. The ld. AR thus prayed that the addition

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:

section 68 of the Act relating to “source of source” introduced by the Finance Act, 2012 is prospective and applicable only from AY 2013–14 onwards. Accordingly, for the year under consideration, the assessee was not required to explain the source of the source. Reliance was placed on decision of the Hon’ble Bombay High Court

M/S ANJENEYA ISPAT LTD.,SARAIKELA vs. DEPUTY COMMISSIONE OF INCOME TAX, CIRCELE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.75/Ran/2022 Assessment Year: 2009-10 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, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 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 “Cit(A)”) Dated 25.09.2017 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 Filed Its Return Of Income For The Assessment Year 2019–20 Declaring A Total Income Of ₹62,64,116. The Case Was Selected For Complete Scrutiny. During The Relevant Previous Year, A Survey Operation Under Section 133A Of The Income-Tax Act, 1961 Was Conducted At The Business Premises Of The Assessee On 16.02.2019. Subsequently, Statutory Notices Under Sections 143(2) & 142(1) Of The Act Were Issued. In Response Thereto, The Assessee Appeared From Time To Time & Furnished Various Details & Documents As Called For. The Same Were Examined & Discussed By The Assessing Officer During The Course Of Assessment Proceedings. During

5,33,60,773, the assessee has already offered additional income of ₹25,00,000, which works out to approximately I.T.A. No.75/Ran/2022 M/s Anjeneya Ispat Ltd 4.68% of the total alleged excess stock, whereas the book profit rate for the year under consideration is only about 2.05%. Thus, even the enhanced addition sustained by the CIT(A) stands adequately covered

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

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

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

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

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

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

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

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

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

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

section 10(38) of the Act was genuine and justified and in no way can be held to be assessed in the hands of assessee’s husband Shri Kamlesh Kr. Singh. Thus the ld. CIT(Appeals) was not justified in confirming the addition substantively in the hands of her husband. Since the alleged LTCG is a genuine

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

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

21. Respectfully following the ratio of the decision of the Hon'ble Delhi High Court in the above cases, we hold that no TP adjustment can be made by deducing from the difference between AMP expenditure incurred by assessee-company and AMP expenditure of comparable entity, if there is no explicit arrangement between the assessee-company and its foreign

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

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)

68 of the Act on account of unsecured loans, rejected the books of account and estimated profit at the rate of 8%, made further additions of ₹1,21,499 on account of sundry receipts, and ₹46,089 on account of profit on sale of assets. 3. Aggrieved, the assessee preferred an appeal before the learned CIT(A). The learned

ACIT CIR-3 (1), DEVGHAR vs. M/S DEOGHAR JAMTARA CENTRAL CO-OPERATIVE BANK LTD , DEOGHAR

In the result, both the revenue’s appeals are dismissed

Bench: Shri S. S. Godara, J.M. & Dr.A.L.Saini, A.M.)

5. Brief facts qua the issue are that the ld. AO has made an addition of Rs. 74, 992/- as accrued Income on Bonds for the period from 01/02/2008 to 31/03/2008, as observed from the assessment order:- “It appears that appellant has invested Rs. 49,99,500/- in NABARD Bhavishya Nirman Bonds on 01.02.2008 which is in the nature