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

SHRI NAVNEET MODI,RANCHI vs. DCIT,CIRCLE-2, RANCHI

In the result, both appeals of the assessee are allowed

Bench: Shri C.M.Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.106/Ran/2019 & आयकर अऩीऱ सं./Ita No.53/Ran/2019 (नििाारण वषा / Assessment Year :2015-2016 & 2013-2014) Shri Navneet Modi, Vs. Dcit, Circle-2, Ranchi Modi House, Kanke Dam Side Road, Kanke, Ranchi स्थायी ऱेखा सं./ Pan No. : Actpm 1511 F (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri Inderjeet Singh, Cit(Dr)

section 68 of the Act. In view of above we find no reason to interfere in the order of ld. CIT(A). Hence this ground of Revenue is dismissed. " 4. The AO in our view was confused. He at para (3) of his order states that the addition u/s 68 of the Act and at para 3.6 states that

KAMESHWAR ALLOYS AND STEELS PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 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, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

2,00,00,000 made under section 68 and sustained by the CIT(A) is deleted. 8. In the result

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)

2. Addition of ₹20,86,500/- under Section 69A of the Act alleged unexplained investment in capital. 3. The CIT(A) granted partial relief but sustained the above additions, against which the assessee is now in appeal before us. Addition under Section 68 – ₹7,40,000/- (Unsecured Loan) The Assessing Officer observed that the assessee had received unsecured

SRI AJAY KUMAR KHATORE,RANCHI vs. DCIT CIRCLE-1, RANCHI

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

Bench: Shri N.S.Saini & Shri Pavan Kumar Gadalea.Y. : 2012-2013 Sri Ajay Kumar Khatore, Vs Dcit, Circle-1, Ranchi North Market Road, Upper Bazaar, Ranchi-834001 Pan No. : Aaacb 7488 C Respondent (Appellant) .

68,000/- cannot be considered as deemed dividend. We have also perused the CBDT Circular No.19/2017, dated 12th June, 2017, placed by the ld. AR of the assessee before us, which reads as under :- “Sub: Settled View on section 2(22We) of the Income Tax Act trade advances -reg. Section 2(22) clause (e) of the Income

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:

8. The Assessee preferred an appeal against the aforementioned assessment order before the Commissioner of Income Tax (Appeals) [CIT(A)] which was allowed vide order dated 16.09.2016. The CIT(A) held that the Assessee had discharged the initial onus under Section 68 of the Act by providing sufficient documents including bank details of the share applicants, copies

M/S MANIKARAN POWER LTD,RANCHI vs. ACIT, CIRCLE-2, RANCHI

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

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 01/Ran/2025 (Assessment Year: 2022-23) A.C.I.T., Manikaran Power Limited, Central Circle-2, Manikaran Tower, Kilburn Colony, Vs. Ranchi. P.O. Hinoo, Ranchi-834002 (Jharkhand) J.C.I.T. (In Situ), Pan No. Aaecm 4555 F Ranchi. Revenue/ Appellant Respondent/ Assessee Manikaran Power Limited, A.C.I.T., Manikaran Tower, Kilburn Colony, Central Circle-2, Vs. P.O. Hinoo, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Aaecm 4555 F Revenue/ Appellant Respondent/ Assessee

2 | 10 IT(SS)A 01/Ran/2025 & ITA 471/Ran/2025 JCIT Vs. Manikaran Power Ltd. It is human to err. If there is no order passed by the Assessing Officer, then obviously post of CIT(A) is required and if there is no order of ld. CIT(A), there is no requirement of the Tribunal so on and so forth. Various stages

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

section 68 of the Act. Doing so results in double addition, which is impermissible in law. While passing the order the ld. CIT(A) correctly appreciated these facts and deleted the addition. We therefore do not find any infirmity in his order. Accordingly, this ground of the Revenue is dismissed. 7. The next issue relates to the addition

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. 8

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

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

2 raised by the Revenue stands dismissed. 11. Ground no. 3 raised by the Revenue relates to addition of Rs. 46,86,305/- made by ld. AO invoking the provisions of Section 68 of the Act. Brief facts relating to the issue are that there was an increase in the capital during the year

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.

2,00,00,000/- represents the brought-forward balance of share application money received in financial year 2011–12 relevant to assessment year 2012–13. 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

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.

2,00,00,000/- represents the brought-forward balance of share application money received in financial year 2011–12 relevant to assessment year 2012–13. 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

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

section 68. Moreover, the Coordinate Bench had allowed the appeal of the assessee on the similar facts and issue for assessment year 2012-13 in ITA No.84/Kol/2024. In that year addition was made u/s 68 of the Act which was deleted by the Tribunal. Since the present case involves I.T.A. No.11/Ran/2024 Golden Goenka Commerce Pvt. Ltd. identical facts, therefore

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

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

8 2012-2013 4,75,36,565 2013-2014 3,64,11,096 • As can be seen from the above table, the quantum of sundry creditors is reducing year to year and there is no unusual trend during the FY relevant to the AY under consideration. Therefore, there is no valid justification for doubting the genuineness of the creditors. Rather

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

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

MARS MERCANTILES PVT.LTD.,DHANBAD vs. ASSISTANT COMMISSIONE OF INCOME TAX, CENTRAL CIRCLE, DHANBAD, DHANBAD

In the result, appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalassessment Year: 2012-13

68 of the Income Tax Act, 1961.” 2 Mars Mercantile Pvt. Ltd., AY: 2012-13. 3. Assessee has taken an additional ground vide its application dated 01.03.2023. The additional ground taken by the assessee reads as under: “1. For that the proceeding initiated u/s. 148 and the order of assessment passed u/s. 147/143

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

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 any documents evidence/proof like bills, vouchers