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 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

68 of the Act and as confirmed by the ld. CIT(A) under Section 37(1) of the Act is unsustainable and consequently we delete the same. 8. In the result, the appeal of the assessee in ITA No. 471/Ran/2024 stands allowed. 9

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

68 of the Act as unexplained cash credit and also disallowed ₹14,182 towards penal expenses. 3. Aggrieved the order of the Assessing Officer, the assessee preferred an appeal before the CIT(A), where the Ld. Commissioner of Income-tax (Appeals) sustained the addition of ₹2,00,00,000. 4. Dissatisfied with the order

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

9 of 10 I.T.A. No.: 94/Ran/2019 Assessment Year: 2015-16 Sanjay Kumar Upadhyay. provisions of Section 68 of the Act which

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)

68 of the Act. 8. Addition under Section 69A of the Act ₹20,86,500/- (Introduction of Capital) The Assessing Officer further noted that the assessee had introduced total capital of ₹27,02,500/- in his proprietary business during the year, of which ₹6,16,000/- was through bank and the balance ₹20,86,500/- was claimed

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

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 and alleged accommodation entries, the Assessing Officer recorded reasons under section 147 of the Act. A notice under section 148 was issued the assessee filed

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

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

9 (xii) During the appellate proceedings, the appellant had filed the confirmation for all the parties and thereafter, remand report was sought from the AO. The remand report is scanned and also printed above. In this regard, the AO in the remand report dated 30.03.2018 in para 2(viii) has stated as under: "During the assessment proceedings ledger account

SANJEEV SABLOK,JAMSHEDPUR vs. ITO WD-1(4), JSR

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

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.147/Ran/2018 (नििाारण वषा / Assessment Year :2010-2011) Sanjeev Sablok, Vs. Ito, Ward-1(4), 4, I.C.Road, Circuit House Area Jamshedpur Bistupur, Jamshedpur-831001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Adkps 4050 M (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri M.K.Choudhary, Advocate राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

Section 68 of the 9 Act. We notice from the bank statements produced at page 19 and 20 of the paper

DCIT, CIRCLE-1, RANCHI vs. M/S A.K.TRANSPORT, RANCHI

In the result, appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

section 68 for making addition of sundry creditors which are appearing as payable in the Balance Sheet. Therefore, the addition of Rs.4,36,89,102/- u/s 68 is hereby deleted. Accordingly, this ground of appeal is allowed.” 5. After hearing the rival contentions and perusing the material on record, we find that the Ld. CIT(A), after taking into

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68

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

9. Having held so, -we may further add that a reading of section 115BBE of the Act makes it clear that the special rate of tax provided under the said provisions shall be applicable under two conditions. Firstly, where the total income includes any income referred to in sections 68