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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

income to such extent as related to the disclosure made u/s. 132(4) of the Act as unexplained investment, unexplained cash credits etc. u/s. 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

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

68 of I.T. Act, the Ld.CIT (A) Hazaribag, erred in deleting the addition. The Ld.CIT (A) Hazaribag, relied upon the evidence put forwarded by the assessee before him in this regard and did not take into account the fact brought on the record by the Assessing officer.” 4. Ld. D/R vehemently argued supporting the finding

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

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

undisclosed sources Although the above are not envisaged in the deeming provisions of section 41(1) for the above issues which is not legally tenable. Section 41 (1) is a deeming section and deeming provision is a statutory fiction; as a rule it implicitly admits that a thing is not what it is deemed to be but decrees that

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

68 of the Act. The AO completed reassessment under section 147 determining the total income at ₹2,26,89,300. 3. Aggrieved, the assessee preferred an appeal before the CIT(A), who deleted the additions observing as under: “Appellate findings: I have heard the rival submissions and perused the orders of the Ld.AO and the material available on record

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

undisclosed investment and added the entire amount of ₹1,07,26,895 as unexplained investment under section 69 of the Act. During physical verification of cash, a difference of ₹4,08,000 was found as compared to the cash balance reflected in the cash book. The assessee explained that on the date of survey, i.e., 16.02.2019, the books of account

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

In the result, appeal of the assessee is allowed and the appeal of the revenue\nis dismissed

68,09,200/- being 150% of the total tax sought\nto be evaded. Being aggrieved with the penalty order, an appeal was filed\nbefore CIT(A) who vide the impugned order dated 15/03/2024, partly\nallowed the appeal filed by the assessee. The CIT(A) NFAC though\ndismissed the legal ground challenging the validity of the notice issued U/s\n274 r.w.s

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

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

68,01,600/- being 150% of the total tax sought to be evaded. Being aggrieved with the penalty order, an appeal was filed before CIT(A) who vide the impugned order dated 15/03/2024, party allowed the appeal filed by the assessee. The CIT(A) NFAC though dismissed the legal ground challenging the validity of the notice issued U/s 274 r.w.s

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

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

68,01,600/- being 150% of the total tax sought to be evaded. Being aggrieved with the penalty order, an appeal was filed before CIT(A) who vide the impugned order dated 15/03/2024, party allowed the appeal filed by the assessee. The CIT(A) NFAC though dismissed the legal ground challenging the validity of the notice issued U/s 274 r.w.s

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

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

68,09,200/- being 150% of the total tax sought to be evaded. Being aggrieved with the penalty order, an appeal was filed before CIT(A) who vide the impugned order dated 15/03/2024, partly allowed the appeal filed by the assessee. The CIT(A) NFAC though dismissed the legal ground challenging the validity of the notice issued U/s 274 r.w.s

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

68,00,000/- (vii) IICM Expenses ₹ 2,40,00,000/- (viii) Depreciation on Lease Hold Land ₹ 8,74,00,000/- (ix) CSR Expenses ₹ 15,52,00,000/- Total Additions/Disallowances ₹ 2,01,52,25,826/- The penalty proceedings under Section 271(1)(c) of the Act were separately initiated with the issue of notice under Section 274 read with section