GOLDEN GOENKA COMMERCE PVT. LTD.,,KOLKATA vs. ACIT CIRCLE-2(1),, JAMSHEDPUR

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

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 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 Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

68 of the Act. Accordingly, the entire amount of ₹4.73 crores was treated as unexplained cash credit and added to the income of the assessee. Apart from the above, the AO also disallowed set-off of certain losses against capital gains and finally assessed the total income at ₹4,89,67,090 vide order dated 21.12.2018. 4. On appeal

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

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

78,735/- and on account of business expenses of Rs. 26,98,782/-. Thereafter, the AR stated that, the AO has accepted the claim on account of purchase of material, business expenses etc. and rightly allowed the claim ITA No.222/R/2019 & C.O.12/R/2019 A.Y. 2014-15 ACIT, Cir-3,RAN Vs. Sh Sumit Ramsisaria Page 7 of these expenses. Having accepted

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

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

68 taxmann.com 311 (Bangalore - Trib.) The Bangalore Tribunal has relied on the decision in the case of Bausch & Lomb Eyecare (India) Pvt. Ltd. Vs. ACIT (2016) 381 117 (Del) and held 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

M/S STEEL CITY FOOD PRODUCTS PVT LTD.,JAMSHEDPUR vs. ACIT, CIRCLE-3, JAMSHEDPUR

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

68 ITD 407. 5 ITA Nos.183/Ran/15 29/Ran/16 & CO No. 21/Ran/17 15. In view of above, we are of the view that the order of the CIT-A on this issue is justified. Thus, ground no. 1 relating to unaccounted purchase and sale raised by the revenue in the appeal is dismissed. 16. Ground no. 2 is relating to deletion

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

CCL,RANCHI vs. DCIT CIR-1, RANCHI

78,37,000\n89,82,07,000\n40,87,00,000\n23,17,26,000\nPA\nAY 2007-08\n165/RAN/2017\nBy Assessee\n17,33,32,000\n74,48,000\n23,16,60,000\nPA\nAY 2008-09\n166/RAN/2017\nBy Assessee\n2,80,62,000\n25,20,60,000\nAY 2009-10\n167/RAN/2017\nBy Assessee

DCIT CIR-1, RANCHI vs. CCL, RANCHI

78,37,000\n89,82,07,000\n17,33,32,000\n74,48,000\n2,80,62,000\n26,65,

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

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

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

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

DCIT CIR-1,, RANCHI vs. CCL, RANCHI

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

CCL,RANCHI vs. ACIT CIR-1, RANCHI

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules

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

78,37,000\n89,82,07,000\n40,87,00,000\n23,17,26,000\n23,16,60,000\n2,20,00,000\n2,13,49,00,000\n19,85,73,000\nPA\nAY 2007-08\n165/RAN/2017\nBy Assessee

CCL,RNCHI vs. ACIT CIR-1 , RANCHI

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

DCIT CIR-1, RANCHI vs. CCL, RANCHI

78,37,000\n17,33,32,000\n2,80,62,000\n26,65,86,000\n3,60,36,000\nLand & Crop Compensation\n89,82,07,000\n74,48,000\nCredit of Dividend Distribution Tax\n40,87,00,000\nRehabilitation fund Contribution Expenses\n23,17,26,000\n23,16,60,000\n25,20,60,000\n26,19,00,000\nIICM Charges

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

78,37,000\n89,82,07,000\nPA\nAY 2007-08\n165/RAN/2017\nBy Assessee\n17,33,32,000\n74,48,000\nPA\nAY 2008-09\n166/RAN/2017\nBy Assessee\n2,80,62,000\nAY 2009-10\n167/RAN/2017\nBy Assessee\n26,65,86,000\nAY 2010-11\n168/RAN/2017\nBy Assessee

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

Section 14A of the Act r.w. Rule 8D of\nthe Rules were applicable on the assessee and after giving a show\ncause computed the disallowance at Rs. 27,19,753/- comprising of\nRs. 9,11,753/- under Rule 8D(2)(ii) and Rs. 17,32,000/- under Rule\n8D(2)(iii) of the Rules