Dhanbad826005. PAN No. AAACB 7934 M Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri M.K. Choudhary with Shri Devesh Poddar, ARs. Department represented by Smt. Rinku Singh, CITDR Date of hearing 11/06/2025 Date of pronouncement 11/06/2025 ORDER PER: BENCH 1. These appeals filed by the assessee(s) are directed against the separate orders of the learned Commissioner of Income Tax (Appeals), Dhanbad [in short, the ld. CIT(A)] all dated 14/03/2018 for the Assessment Years (AY) 200708 to 201213. Since all the appeals have identical facts and grounds except variation in the amount of penalty, therefore, all these appeals are clubbed and heard together and are being decided by this common order. As a lead case, we take ITA No. 121/Ran/2018 for the A.Y. 200708, in this appeal, the assessee has raised following grounds of appeal: "1. For that Ld. CIT(A) was not justified in confirming the order imposing penalty passed by Ld. A.O. Order of penalty was passed ignoring the provision of section 275 since appeal filed for quantum was pending before Hon'ble ITAT for hearing. U. A.O. Imposed penalty without considering merits of the addition. 2. For that Ld. A.O. initiated penalty proceeding as per assessment order which states that "that the penalty proceeding U/s 271 (1) (C) initiated". In the notice ITA No. 121/Ran/2018 BCCL Vs ACIT & ors 5 appeals of penalty also, it is not specified as to whether penalty was initiated for concealment of income or for furnishing inaccurate particulars of income. Ld. CIT(A) has tried to distinguish the decisions of Hon'ble Apex Court and various High Courts, which was cited by the appellant to suggest that initiation of penalty proceeding was vague, as such, order imposing penalty was illegal. 3. For that out of total disallowed contractual expenditure of Rs. 12.44 Cr, Rs. 0.13 Cr relates to capital work and Rs. 12.32 Cr relates to revenue work as reported by DGIT (Investigation, Patna) vide its report dated 09.01.2014. However, an amount of Rs. 5.14 Cr was only charged to P&L A/C as per the audited accounts, the details of which were furnished before CIT(A) on 19.06.2017 during the course of hearing. The payment was made based on certification of work done by different authorities of BCCL. 4. Further, the disallowance of contractual expenses of Rs. 7.53 Cr is comprised of Rs. 5.14 Cr related to Kustore area and the balance Rs. 2.39 Cr related to PB Area. The expenditure disallowed for want of party wise details at the time of assessment is unjustified. As stated above, the party wise details of Rs 7.53 Cr were already furnished to CIT (A) on 19.06.20 17 during the course of hearing. The expenses incurred were verified by internal auditor, statutory auditor and CAG thereafter only accounts were finalised and passed by board of directors of the appellant. 5. For that the addition made in the order of assessment as confirmed by Ld. CIT(A) are in dispute before Hon'ble ITAT. None of the additions made can be considered as concealment of income. Further, none of the additions will come under purview of furnishing inaccurate particulars. Ld. AO was therefore not justified in imposing penalty U/s 271(1)(c). 6. For that other grounds in details will be argued at the time of hearing." 2. The brief facts of the case are that the appellant company, a public sector undertaking (PSU) and a subsidiary company of M/s Coal India Ltd (CIL), is engage