IN THE INCOME TAX APPELLATE TRIBUNAL PATNA BENCH, PATNA BEFORE SHRI DUVVURU RL REDDY, VP AND SHRI RAJESH KUMAR, AM ITA Nos. 34 & 35/PAT /2021 (AY: 2011-12 & 12 -13)

ACIT, Central Circle-3 Vs Ashok Kumar Bagaria, Patna. 502 & 503, Shanti Vihar Apartment, Frazer Road, Patna.

(APPELLANT) (RESPONDENT)

PAN No. ADAPB9497P Assessee by: Sh. A.K. Rastogi, Sr. Adv. And Sh. Rakesh Kumar, Adv.

Revenue by: Md. A. H. Chowdhary, CIT (DR).

Date of Hearing: 24.11.2025 Date of Pronouncement: 23.02.2026

ORDER

Per Rajesh Kumar, AM:

These appeals are preferred by the Revenue against the orders of the Commissioner of Income -tax (Appeals), Patna-3 (hereinafter referred to as the “Ld. CIT(A)’} even dated 11.02.2021 for the A.Ys.2011-12 and 2012-13.

2. As the facts and circumstances in both the appeals are exactly similar , these are being disposed off by this common order for the sake of convenience and berevity. Hence, we first take ITA No.34/PAT/2021 and decide the appeal accordingly.

2. The only issue raised by the Revenue in this appeal is against order of the learned CIT (A) deleting the addition of Rs.3,02,00,000/- u/s 69 of the Act as was made by the AO in respect of share capital by treating the same as