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

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

5, 15 (Salaries), 22 (Income from house property), 28 (Profits and gains of business), 45 (Capital gain) and 56 (Income from other Sources). Even Income arising from International Transaction between A.E. must satisfy the test of Income under the Act and must find its home in one of the above heads i.e. charging provisions..... iv. Dana Corporation [2010] 186 Taxman

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)

68,84,000/- 4. Total 11,60,00,000/- It is therefore clear that the objection of assessee is not tenable as the disclosure is related to only one assessee i.e. Padam Kr. Jain. It is important to mention here that the amount of disclosure is not in round figure, which itself clarifies that the disclosure is based on fact

ACIT CIRCLE-1, DHANBAD vs. SRI VIKASH AGARWAL, DHANBAD

In the result, grounds of appeal raised by the revenue is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri Ratnesh Nandan Sahay

45,610/-. The case was selected for limited scrutiny under E-assessment Scheme, 2019 on the following two issues (i) unsecured loans and (ii) income from house property. During the assessment proceedings, the Assessing Officer noticed from the ACIT Vs Sri Vikash Agarwal audit report filed by the assessee that the assessee has taken unsecured loans of ₹ 1.00 crore from

SHRIRAM MARKETING SERVICES,GIRIDIH vs. PCIT, DHANBAD

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 263 of the Act dated 26/12/2022, set aside the order of Assessing Officer dated 24/09/2021 on the ground that the Assessing Officer did not make any enquiry or investigation to ascertain the nature, source and genuineness of ₹ 2,68,72,976/- and directed the Assessing Officer to make a fresh assessment on the issues discussed above because

M/S S.P.ENTERPRISES,JAMSHEDPUR vs. ITO WARD-1(5), JAMSHEDPUR

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2010-11

45,580/- and disallowed @ 20% thereon Rs.15,69,116/-. It is also made clear that without the payment being made by bearer cheque these goods could not have been procured and it would have hampered the supply of goods within the stipulated time. Therefore, the genuineness of the purchase has been accepted by the Id. CIT (Appeal) which has also

M/S S.P ENTERPRISES,JAMSHEDPUR vs. DCIT, JAMSHEDPUR

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2010-11

45,580/- and disallowed @ 20% thereon Rs.15,69,116/-. It is also made clear that without the payment being made by bearer cheque these goods could not have been procured and it would have hampered the supply of goods within the stipulated time. Therefore, the genuineness of the purchase has been accepted by the Id. CIT (Appeal) which has also

M/S S.P.ENTERPRISES,JAMSHEDPUR vs. ITO WARD-1(5), JAMSHEDPUR

Bench: Shri S.S.Godara & Dr. A.L. Sainiassessment Year :2010-11

45,580/- and disallowed @ 20% thereon Rs.15,69,116/-. It is also made clear that without the payment being made by bearer cheque these goods could not have been procured and it would have hampered the supply of goods within the stipulated time. Therefore, the genuineness of the purchase has been accepted by the Id. CIT (Appeal) which has also

ACIT, CIRCLE-1(1), DHANBAD vs. M/S HIMANGSU MAHTO, DHANBAD

In the result, the appeal filed by the Revenue in ITA No

Bench: Sri Rajesh Kumar & Sonjoy Sarma

5. After hearing rival contentions and perusing the material on record, we find that the assessee has taken unsecured loan of Rs. 2,44,45,000/- from M/s. Royal Securities Ltd. We also note that the opening balance brought forward from the preceding previous was Rs. 10,50,786/- with amount borrowed during the of Rs. 2,44,45

INDIAN PROGRESSIVE CONSTRUCTION PVT. LTD.,,DEOGHAR vs. DCIT CIRCLE-3,, DEOGHAR

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 68 of the Act i.e. the identity of the parties, their creditworthiness and the genuineness of the transactions. 4. Aggrieved by the order of the ld. CIT(A), this appeal has been preferred before this Tribunal. 5. During the appellate proceedings before us, the appellant has submitted paper book wherein it has been submitted as under: "As required

KAUSHAL JAIN,RANCHI vs. ITO, WARD-1(5), RANCHI

In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Kaushal Jain, I.T.O., Radheshyam Garage Lane, Old Ward 1(5), Vs. Commissioner Compound, Ranchi. Ranchi-834001 (Jharkhand) Pan No. Afgpj 0706 H Appellant/ Assessee Respondent/ Revenue

Section 69A of the Income Tax Act, 1961 (in short, the Act) on the ground that the assessee failed to explain the cash deposits of ₹ 52,16,169/-. The Assessing Officer in the assessment order has also given the basis on which the addition was made by providing a table in the assessment order in paragraph

ITO.WD-2(1), RANCHI vs. SHRI NAND BIHARI SHRIVASTAVA, RANCHI

In the result, the revenue’s appeal is dismissed

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

section 56(2)(vii) of the I.T Act, 1961. 5. Brief facts qua the issue are that the assesse is a retired bank employee. Since no notice could be served upon him, he was not able to adduce evidences on his behalf. The appellant stated before AO that the property at village Pandara consisting of a house and land

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 143(3) of the Income Tax Act, 1961 (in short, the Act) on 28/12/2018 by making addition of Rs. 68,36,208/- on the ground that an examination of Audited 'Rental Account' of the assessee shows that the Gross Annual Value, on which standard deduction was claimed, includes receipts from cinema amounting

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

45,02,000\n1,51,00,000\n8\nDirectors Salary - Adl. Ground Not Admitted by\nCIT(A)\n74,61,000\n1,12,62,000\nTotal Rs.\n61,89,37,000\n1,39,37,68,000\n74,89,09,000\n13. The first issue is in regard to addition made on contractual expenses\nrelated to Kustore area (L.B.Singh). It was submitted

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

45,02,000\n1,51,00,000\n8\nDirectors Salary - Adl. Ground Not Admitted by\nCIT(A)\n74,61,000\n1,12,62,000\nTotal Rs.\n61,89,37,000\n1,39,37,68,000\n74,89,09,000\n13. The first issue is in regard to addition made on contractual expenses\nrelated to Kustore area (L.B.Singh). It was submitted

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

45,02,000\n1,51,00,000\n8\nDirectors Salary - Adl. Ground Not Admitted by\nCIT(A)\n74,61,000\n1,12,62,000\nTotal Rs.\n61,89,37,000\n1,39,37,68,000\n74,89,09,000\n13. The first issue is in regard to addition made on contractual expenses\nrelated to Kustore area (L.B.Singh). It was submitted

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

45,02,000\n1,51,00,000\n8 Directors Salary - Adl. Ground Not Admitted by\nCIT(A)\n74,61,000\n1,12,62,000\nTotal Rs.\n61,89,37,000\n1,39,37,68,000\n74,89,09,000\n13.\nThe first issue is in regard to addition made on contractual expenses\nrelated to Kustore area (L.B.Singh). It was submitted

DCIT,CIRCLE-1RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

In the result, appeal of the assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.164,165,166,167,168,169,170&266/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita Nos.32/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.190 & 191/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.119, 120, 74/Ran/2024 (Ay: 2018-19, 2019-20 & 2020-21) M/S Central Coalfields Limited, Vs. Addl.Cit, Range-1, Ranchi Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R & आयकर अपील सं./Ita Nos.172,173,174,175,176,177,178 & 235/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita No.37/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.174 & 175/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.47, 203, 204, 128/Ran/2024 (Ay: 2017-2018, 2018-19, 2019-20 & 2020-21) Addl.Cit, Range-1, Ranchi Vs. M/S Central Coalfields Limited, Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (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 : 05/01/2026 घोषणा की तारीख/Date Of Pronouncement : 05/01/2026 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 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

5 M/s Central Coal Fields Ltd. figures in the computation. Thus, this issue is partly allowed for statistical purposes. 6. Next issue is with regard to disallowance land and crop compensation. It was submitted by the Ld.AR that for the purpose of mining to reach the coal layer the assessee has to remove the soil from

M/S. CENTRAL COAL FIELDS LTD.,,RANCHI vs. ACIT/DCIT, CIRCLE-1, RANCHI

In the result, appeal of the assessee in ITA No

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita Nos.164,165,166,167,168,169,170&266/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita Nos.32/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.190 & 191/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.119, 120, 74/Ran/2024 (Ay: 2018-19, 2019-20 & 2020-21) M/S Central Coalfields Limited, Vs. Addl.Cit, Range-1, Ranchi Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R & आयकर अपील सं./Ita Nos.172,173,174,175,176,177,178 & 235/Ran/2017 (A.Y :2006-07, 2007-08, 2008-09, 2009-10, 2010-11, 2011-12, 2012-13, 2013-14) आयकर अपील सं./Ita No.37/Ran/2018 (Ay : 2014-2015) आयकर अपील सं./Ita Nos.174 & 175/Ran/2019 (Ay:2015-16 & 2016-17) आयकर अपील सं./Ita Nos.47, 203, 204, 128/Ran/2024 (Ay: 2017-2018, 2018-19, 2019-20 & 2020-21) Addl.Cit, Range-1, Ranchi Vs. M/S Central Coalfields Limited, Darbhanga House, Office Of Gm Finance-A, Opp. Governor House Ranchi-834001 स्थायी लेखा सं./Pan No. : Aaacc 7476 R (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 : 05/01/2026 घोषणा की तारीख/Date Of Pronouncement : 05/01/2026 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 12.04.2017, 26.04.2017, 25.04.2027, 28.04.2017, 08.11.2017

5 M/s Central Coal Fields Ltd. figures in the computation. Thus, this issue is partly allowed for statistical purposes. 6. Next issue is with regard to disallowance land and crop compensation. It was submitted by the Ld.AR that for the purpose of mining to reach the coal layer the assessee has to remove the soil from