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2025 Supreme(Online)(ITAT) 2419

INCOME TAX APPELLATE TRIBUNAL (RANCHI BENCH)
Shri Partha Sarathi Chaudhury, Shri Ratnesh Nandan Sahay, JJ
Assistant Commissioner of Income Tax, Central Circle-2, Ranchi – Appellant
Versus
M/s Heighten Construction – Respondent


Advocates:
For the Appellants/Petitioners: Not mentioned
For the Respondents: Not mentioned

Table of Content
1. essence of appeals and delay due to pandemic (Para 1 , 3 , 4)
2. fundamental payments and contention under section 40a(3) (Para 6 , 12 , 13 , 14)
3. findings on the genuineness of cash payments (Para 7 , 11 , 15 , 18)
4. conclusion and dismissal of revenue appeal (Para 20 , 21)

ORDER

PER: BENCH

1. These appeals preferred by the revenue as well as by the assessee emanates from the separate orders of learned Commissioner of Income Tax (Appeals)-3, Patna [in short, the ld. CIT(A)] dated 17/02/2020 and 18/02/2020 for the Assessment Year (AY) 2011-12 to 2016-17 respectively as per the grounds of appeal on record.

2. At the outset, the parties herein conceded that the facts and circumstances and the issues involved in all these appeals are absolutely similar and identical and after hearing the submissions of both the parties, all the matters are heard together and are disposed off vide this consolidated order.

3. These appeals are time barred as per number of dates appearing against each one of them as per record. We have considered the condonation petition and the reasons for the delay and we find that such delay cannot be attributed to the deliberate or malafide conduct of t

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