Hindustan Steel Ltd. v. State of Orissa

83 ITR 26Supreme Court of India1972#134 most cited

What is Hindustan Steel Ltd. v. State of Orissa authority for?

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

502

judgments rely on this decision, according to BharatTax’s citation analysis of 371,239 Indian tax judgments — from 2011 to 2026.

Also referred to as

Hindustan Steel Ltd v State of Orissa · 83 ITR 26 SC · levy of penalty · quasi-criminal proceedings · statutory obligation default · deliberate defiance · contumacious conduct · dishonest conduct · conscious disregard · section 271(1)(c) · section 272A · section 273B

Sections most often in play

Section 273BSection 142(1)Section 271(1)(b)Section 272A(1)(d)Section 143(2)Section 143(3)Section 271(1)(c)Section 274

Issues it is cited on

section 273section 273bsection 272asection 271esection 271csection 271bsection 271fsection 271dsection 271(1)(b)section 271aalevy of penaltysection 271a

Judgments citing Hindustan Steel Ltd. v. State of Orissa

Asset Motors Private Limited, Mumbai vs. DCIT 15 (1)(1), Mumbai

ITA 1463/MUM/2019[2011-12]Status: DisposedITAT Mumbai31 Aug 2021AY 2011-12

Bench: Shri C.N. Prasad () & Shri S. Rifaur Rahman () Assessment Year: 2011-12 Asset Motors Private Limited, Deputy Commissioner Of Income Bungalow No. 3, Plot No. 14, Union Vs. Tax-15(1)(1), Park, Chembur, Room No. 470, 4Th Floor, Aayakar Mumbai-400071. Bhavan, Maharshi Karve Road, Churchgate, Mumbai-400020. Pan No. Aahca 7847 F Appellant Respondent

For Appellant: Mr. Prasad Paranjape, ARFor Respondent: Mr. Brajendra Kumar, DR
Section 143(3)Section 271Section 271(1)(c)Section 274Section 35DSection 36(1)(iii)

…self lead to the inference that the assessee had in accurate particulars in regard to that item. h) Our client further invite your attention to the following observation made by the by the Supreme Court in the case of Hindustan Steel Ltd. vs. State of Orissa (83 ITR 26). An order imposing penalty for failure to carry out a statutory obligation is the result of a quasi-criminal proceedings and penalty will not ordinarily be imposed unless the party obliged, either acted deliberately in defiance of law or was guilty of conduct contumacious or dishonest or acted in conscious disregard its obligation. Penalty will no…

Pal Gram Hindu Sarvajanik Trust, Surat vs. Income Tax Officer, Exemption Ward, Surat

In the result, appeal filed by the assessee is allowed

ITA 536/SRT/2018[2011-12 ]Status: DisposedITAT Surat29 Jul 2021

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.536/Srt/2018 ("नधा"रणवष" / Assessment Year: (2011-12) (Virtual Court Hearing) Pal Gram Hindu Sarvajanik Trust, V The Income Tax Officer, At 7 Post : Pal, Tal. Choryasi, Exemption Ward, Surat. S. Dist – Surat – 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatp 2544 G (Assessee) (Respondent) Assessee By : Shri Hiren Vepari - Ca Respondent By : Ms.Anupama Singla – Sr.Dr सुनवाईक"तार"ख/ Date Of Hearing : 02/07/2021 घोषणाक"तार"ख/Date Of Pronouncement : 29/07/2021 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2011-12 Is Directed Against The Order Passed By The Ld.Commissioner Of Income Tax(Appeals)-3, Surat [Ld.Cit(A)] Dated 30.05.2018, Which In Turn Arises Out Of A Penalty Order Passed By The Assessing Officer Under Section 271(1)(C) Of 1The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”], Dated 24.03.2017. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “[1] On The Facts & Circumstances Of The Case, The Learned Cit(A) Was Not Justified In Confirming Penalty U/S 271(1)(C) Of The Act. [2] With The Assessing Officer Failing To Specify In The Assessment Order As To Whether The Proceedings Were Initiated For Concealing Income Or Furnishing Inaccurate Particulars Of Income, The Penalty Order Was Required To Be Knocked Down In View Of The Decision Of The Gujarat High Court In Case Of Sorathia Engineering Co. Ltd. (282-Itr-642). [3] The Assessee Craves Leave To Add, Alter Or Vary Any Of The Grounds Of Appeal.”

For Appellant: Shri Hiren Vepari - CAFor Respondent: Ms.Anupama Singla – Sr.DR
Section 11Section 11(1)(a)Section 11(2)Section 142(1)Section 22Section 271Section 271(1)Section 271(1)(c)

…the assessee in default as an offence, if it is proved that it was caused by willful failure. These are the three varying degrees of defaults and the statute clearly keeps up the distinction between the three modes. In Hindustan Steel Ltd. v. State of Orissa [83 ITR 26), the Hon`ble Supreme Court observed that whether the penalty should be imposed for failure to perform a ITA No.536/SRT/2018 for A.Y. 2011-12 statutory obligation is a matter of discretion of the authority to be exercised judicially and on a consideration of all relevant circumstances and that even if a minimum penalty is prescribed the authority…

M/S Aanya Real Estate Pvt Ltd, Mumbai vs. Dy CIT 15 (1)(1), Mumbai

In the result, we set aside the orders of the authorities below and direct that the penalty in this case be deleted

ITA 115/MUM/2020[2011-12]Status: DisposedITAT Mumbai20 Jul 2021AY 2011-12

Bench: Shri Shamim Yahya, Am & Shri Pavan Kumar Gadale, Jm M/S. Aanya Real Estate Pvt. Ltd. Dy. Cit 15(1)(1) R. No. 470, 4Th Floor, 120 A Wing 02, Commercial Building 23-24, Aayakar Bhavan, M. K. Road, Vs. Minerva Industrial Estate, Aasha Nagar, Mumbai-400 020 Mulund (W), Mumbai-400 080

For Appellant: Shri K. P. DewaniFor Respondent: Shri Brajendra Kumar
Section 115JSection 143(3)Section 271Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE SHRI SHAMIM YAHYA, AM AND SHRI PAVAN KUMAR GADALE, JM M/s. Aanya Real Estate Pvt. Ltd. Dy. CIT 15(1)(1) R. No. 470, 4th Floor, 120 A Wing 02, Commercial Building 23-24, Aayakar Bhavan, M. K. Road, Vs. Minerva Industrial Estate, Aasha Nagar, Mumbai-400 020 Mulund (W), Mumbai-400 080 PAN/GIR No. AAGCA 6193 D (Appellant) (Respondent) : Appellant by : Shri K. P. Dewani Respondent by : Shri Brajendra Kumar Date of Hearing : 14.07.2021 : 20.07.2021 Date of Pronouncement O R D E R Per Shamim Yahya, A. M.: This appeal by the assessee is directed against t…

Income Tax Officer-12(3) (3), Mumbai vs. Mahalaxmi Dyes and Chemicals Limited, Mumbai

In the result revenue's appeal is dismissed

ITA 6183/MUM/2019[2011-12]Status: DisposedITAT Mumbai20 Jul 2021AY 2011-12
Section 143(3)Section 271Section 271(1)(c)

…annot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of the Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 6. We further note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case 3 M/s. Mahalaxmi Dyes and Chemicals Limited that since the ad…

Asst. CIT 23 (2), Mumbai vs. Purshottamdas Agarwal, Mumbai

In the result revenue’s appeals are dismissed

ITA 6777/MUM/2019[2010-11]Status: DisposedITAT Mumbai14 Jul 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt () & Shri Shamim Yahya ()

Section 271(1)(c)

…annot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of Hindustan Steel Ltd. Vs. the State of Orissa (83 ITR 26), where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 6. We further note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case that since the addition was made pursuant to information from s…

M/S Unicom Accessories Pvt. Ltd, Mumbai vs. ITO-11(1)(4), Mumbai

Appeals are disposed off in terms of our aforesaid observations

ITA 5420/MUM/2019[2013-14]Status: DisposedITAT Mumbai11 Jun 2021AY 2013-14

Bench: Shri Rajesh Kumar () & Shri Ravish Sood () M/S Unicon Accessories Pvt. Income Tax Officer -11(1)(4) Ltd., 1St Floor, Sheela Niwas, Vs. 2Nd Floor, Aayakar Bhavan, Ramabai Chemburkar Marg, M.K. Road, Churchgate, Vile Parle (East), Mumbai - 400020 Mumbai – 400057

For Appellant: Shri Prakash K. Jotwani, A.RFor Respondent: Ms. Usha Gaikwad, D.R
Section 115JSection 143(1)Section 143(3)Section 147Section 271(1)(c)Section 274Section 40

…infraction of a statutory provision would justify saddling the assessee with penalty under Sec. 271(1)(c) of the Act. At this stage, we are reminded of the judgment of the Hon’ble Supreme Court in the case of Hindustan Steel Limited Vs. State of Orissa (1972) 83 ITR 26(SC), wherein the Hon‟ble apex court had observed that imposition of penalty under Sec. 271(1)(c) is nothing short of a quasi criminal proceedings. In the backdrop of our aforesaid deliberations, we are of a strong conviction that no penalty under Sec. 271(1)(c) for a simpliciter disallowance under Sec.40(a)(ia) could have been validly imposed by th…

ACIT 13 (3)(2), Mumbai vs. M/S Vako Sales Pvt Ltd., Mumbai

In the result, both the appeals by Revenue are dismissed

ITA 6253/MUM/2019[2009-10]Status: DisposedITAT Mumbai02 Jun 2021AY 2009-10
Section 271(1)(c)

…ee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26) where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 3 M/s. Vako Sales Pvt. Ltd. 5. We further note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case that since the addition was made pu…

Mukesh Kamleshwar Batt, Delhi vs. ITO -1(2)(1), Mumbai

In the result, this appeal by the assessee stands allowed

ITA 273/MUM/2019[2014-15]Status: DisposedITAT Mumbai01 Jun 2021AY 2014-15

Bench: Shri Shamim Yahya, Am & Ram Lal Negi, Jm Mukesh Kamleshwar Bhatt Ito(International Taxation)-1(2)(1) C/O Khiwani & Co. 23/36 Room No.10, Scindia House 2Nd Floor, Main Market Vs. Ballard Pier East Patel Nagar, New Delhi Mumbai-400 038 Delhi-110 008 Pan/Gir No. Aijpb5263F (Appellant) : (Respondent)

For Appellant: NoneFor Respondent: Shri Bharat Andahle - DR
Section 143(3)Section 271Section 271(1)(c)Section 274Section 54

…of the assessee is denied the same cannot ipso fact lead to the conclusion that the assessee is guilty of concealment or furnishing of inaccurate particulars of income. Furthermore, Hon’ble Supreme Court in the case of Hindustan Steel Ltd. vs State of Orissa 83 ITR 26 has also expounded that if the conduct of the assesee is not found to be contumacious the authority may not levy penalty. 4 273/Mum/2019 11. In the background of aforesaid discussion and precedent in our considered opinion assessee does not deserve to be visited with the rigors of penalty u/s 271(1)(c). Ld.CIT(A) has completely erred in observing…

A.N. School Shiksha Samiti, Sikar vs. JCIT-Range (Exemption), Jaipur

In the result, this appeal of the assessee is allowed

ITA 252/JPR/2020[2010-11]Status: DisposedITAT Jaipur24 May 2021AY 2010-11

Bench: Shri Sandeep Gosain, Jm & Shri Vikram Singh Yadav, Am Vk;Dj Vihy La-@Ita No. 252/Jp/2020 Fu/Kzkj.K O"Kz@Assessment Year :2010-11 A.N. School Shiksha Samiti, Cuke J.C.I.T.-Range Vs. Radha Swami Bag, (Exemption) Sikar-303702 Jaipur. Lfkk;H Ys[Kk La-@Thvkbzvkj La-@Pan/Gir No.: Aabaa 6164 F Vihykfkhz@Appellant Izr;Fkhz@Respondent Fu/Kzkfjrh Dh Vksj Ls@ Assessee By : Shri Shravan Kr Gupta (Adv) Jktlo Dh Vksj Ls@ Revenue By: Smt. Monisha Choudhary(Jcit) Lquokbz Dh Rkjh[K@ Date Of Hearing : 25/03/2021 Mn?Kks"K.Kk Dh Rkjh[K@ Date Of Pronouncement : 24/05/2021 Vkns'K@ Order Per: Sandeep Gosain, J.M. This Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Cit(A)-3, Jaipur Dated 06/09/2019 For The A.Y. 2010-11 Wherein Following Grounds Have Been Taken. “1. The Impugned Penalty Order U/S 272A(2)(E) Dated 02/11/2018 As Well As Notices Are Bad In Law & On Facts Of The Case, For Want Of Jurisdiction & Various Other Reasons & Hence The Same May Kindly Be Quashed. 2. The Ld. Cit(A) Has Grossly Erred In Law As Well As On The Facts Of The Case In Confirming The Imposition Of Penalty Of Rs. 2,53,700/- U/S 272A(2)(E) Invoked By The Ld Jcit. The Penalty So Imposed & Confirmed By The Ld. Cit(A) Being Totally Contrary To The Provisions Of Law & Facts On The Record & Hence The Same May Kindly Be Deleted.

For Appellant: Shri Shravan Kr Gupta (Adv)For Respondent: Smt. Monisha Choudhary(JCIT)
Section 272A(2)(e)Section 272a(2)(e)Section 5

…merely technical and venial breach of law and the conduct of the assessee has not been shown to be contumacious. No deliberate defiance of law is established. It has been held that by the Honble Supreme Court in the case of Hindustan Steels v/s State of Orisa 83 ITR 26 (SC). "That in order to impose penalty for failure to carry out a statutory obligation is the result of quasi criminal proceedings and penalty will not ordinarily be imposed, unless the party obliged either acted deliberately in defiance of law or was guilty of conduct contumacious or dishonest or acted in conscious disregard of its obligation. The…

Addt. CIT 32 (1), Mumbai vs. Shri. Chandraiah Balanna Kalal, Mumbai

In the result, Revenues 's appeal is dismissed

ITA 6287/MUM/2019[2011-12]Status: DisposedITAT Mumbai03 May 2021AY 2011-12

Bench: Us.

Section 271(1)(c)

…THE INCOME TAX APPELLATE TRIBUNAL “C” Bench, Mumbai Shri Shamim Yahya (AM) & Shri Pavankumar Gadale (JM) I.T.A. No. 6287/Mum/2019 (Assessment Year 2011-12) Vs. Shri Chandraiah ACIT-32(1) Room No. 702 Balanna Kalal 7th Flooor, Kautilya Plot No. 71, Bhavan Dimandar CHSL Bandra Kurla RSC 21, Gorai-1 Complex Borivali West Bandra East Mumbai-400 092. Mumbai-400 051. PAN : AABPK8755H (Appellant) (Respondent) Assessee by Shri Sumit Mantri Department by Shri Brajendra Kumar Date of Hearing 29.04.2021 Date of Pronouncement 03.05.2021 O R D E R Per Shamim Yahya (AM) :- This appeal by the revenue is against order's of…

Shri Anis Ahmed Abdul Rashid Siddiqui, Mumbai vs. ITO - 26(1)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 5907/MUM/2019[2010-11]Status: DisposedITAT Mumbai06 Apr 2021AY 2010-11

Bench: Us.

Section 271(1)(c)

…been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court honourable Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 6. In the background of the aforesaid discussion and precedent, we set aside the orders of learned CIT(A) and delete the levy of penalty. 7. In the result, both the appeals by the assessee are allowed. Pronounced in…

Anwar Abdul Haq Qureshi, Mumbai vs. ACIT-21(1), Mumbai

In the result, both assessee’s appeals are allowed

ITA 5859/MUM/2019[2008-09]Status: DisposedITAT Mumbai06 Apr 2021AY 2008-09
Section 271Section 271(1)(c)

…ee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 8. In the background of aforesaid discussion and precedent we set aside the order's of Ld CITA and delete the levy of penalty. 9. In the result, both assessee’s appeals are allowed. Pronounced in the open court on 6…

DCIT Circle-1, Thane vs. Shri Dalersingh Mathadu, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4573/MUM/2019[2010-11]Status: DisposedITAT Mumbai01 Apr 2021AY 2010-11

Bench: Us.

Section 271(1)(c)

…essee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the Hon'ble Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), wherein it was held that the authority may not levy penalty if the conduct of the assessee is not found to be contumacious. Moreover, it is also noted that the tax effect in this case is below the limit fixed by CBDT for filing appeal before the Tribunal. The plea that addition was based on sales tax department has nothing to do with penalty unde…

ITO, Ward-1(2), Thane vs. Smt. Manisha Kiran Savar, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4564/MUM/2019[2011-12]Status: DisposedITAT Mumbai01 Apr 2021AY 2011-12

Bench: Us.

Section 271(1)(c)

…essee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the Hon'ble Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), wherein it was held that the authority may not levy penalty if the conduct of the assessee is not found to be contumacious. Moreover, it is also noted that the tax effect in this case is below the limit fixed by CBDT for filing appeal before the Tribunal. The plea that addition was based on sales tax department has nothing to do with penalty unde…

ITO, Ward 1(2), Thane vs. Smt. Maniben Manshi Bauva, Thane

In the result, Revenue’s appeal is dismissed

ITA 4563/MUM/2019[2011-12]Status: DisposedITAT Mumbai01 Apr 2021AY 2011-12

Bench: Us.

Section 271(1)(c)

…essee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the Hon'ble Supreme Court in the case of Hindustan Steel Ltd. Vs. State of Orissa (83 ITR 26), wherein it was held that the authority may not levy penalty if the conduct of the assessee is not found to be contumacious. Moreover, it is also noted that the tax effect in this case is below the limit fixed by CBDT for filing appeal before the Tribunal. The plea that addition was based on sales tax department has nothing to do with penalty unde…

ITO-5(2)(3), Mumbai vs. M/S Mokalsar Steel Pvt. Ltd., Mumbai

In the result, Revenue’s appeal is dismissed

ITA 5211/MUM/2019[2011-12]Status: DisposedITAT Mumbai12 Mar 2021AY 2011-12
Section 143(3)Section 148Section 271(1)(c)

…e cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a Larger Bench of the honourable Supreme Court in the case of Hindustan Steels Ltd. Vs. State of Orissa (83 ITR 26) where in it was held that the authority may not levy the penalty if the conduct of the assessee is not found to be contumacious. 3 M/s. Mokalsar Steel Private Limited 6. We further note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case that since the addition wa…

DCIT-5(2), Mumbai vs. M/S. Maruti Inox (India) Pvt. Ltd. (Formerly Known M/S Sansani Steel Pvt. Ltd.), Mumbai

In the result revenues 's appeal is dismissed

ITA 5226/MUM/2019[2011-12]Status: DisposedITAT Mumbai11 Mar 2021AY 2011-12
Section 143(3)Section 148Section 271Section 271(1)(c)

…e cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of Hindustan Steels Ltd. Vs. State of Orissa (83 ITR 26) where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 3 M/s. Maruti Inox (India) Pvt. Ltd. 6. We farther note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case that since the addition wa…

Manisha Rubber Enterprises, Mumbai vs. ITO Ward 29 (2)(3), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 4862/MUM/2019[2010-11]Status: DisposedITAT Mumbai11 Mar 2021AY 2010-11

Bench: Us.

Section 271(1)(c)

…annot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of the Hindustan Steel Ltd. Vs. state of Orissa (83 ITR 26) where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 5. In the result, appeal filed by the assessee is allowed. Pronounced in the open court on 11.3.2021. (RAMLAL NEGI) ACCOUNTANT MEMBER Mumbai; Dated : 11/03/2021 Copy of the Order forwarded to : 1. The Appellant 2. The…

DCIT Cirlce-3, Thane vs. Shri. Surendrakumar Mangturam Sharma, Thane

In the result, both revenues 's appeals are dismissed

ITA 3731/MUM/2019[2011-12]Status: DisposedITAT Mumbai11 Mar 2021AY 2011-12
Section 271(1)(c)

…essee cannot be said to have been guilty of concealment or furnishing of inaccurate particulars of income. In this regard we draw support from the decision of a larger bench of the honourable Supreme Court in the case of Hindustan Steels Ltd. state of Orissa (83 ITR 26) where in it was held that the authority may no t levy the penalty if the conduct of the assessee is not found to be contumacious. 11. We further note that tax effect in this case is below the limit fixed by CBDT for filing appeals before ITAT. The revenue has tried to make out a case that since the addition was made pursuant to information from s…

ITO 25 (3)(3), Mumbai vs. Rajan Nanalal Shanghvi, Mumbai

In the result, the Revenues 's appeal is dismissed

ITA 4919/MUM/2019[2009-10]Status: DisposedITAT Mumbai09 Mar 2021AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Ram Lal Negi, Jm Income Tax Officer-25(3)(3) Rajen Nanalal Shanghvi Room No. 233, 2Nd Floor, B-701, Swapnalok, Kautilya Bhawan, Vs. Dixit Road, Vile Parle (E), Bandra Kurla Complex, Mumbai-400 057 Bandra (E), Mumbai-400 051 Pan/Gir No. Aaeps 4098 N (Appellant) (Respondent) : Appellant By : Shri Bharat Andhle Respondent By : Ms. Kinjal Bhuta Date Of Hearing : 09.03.2021 : 09.03.2021 Date Of Pronouncement

For Appellant: Shri Bharat AndhleFor Respondent: Ms. Kinjal Bhuta
Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI SHAMIM YAHYA, AM AND SHRI RAM LAL NEGI, JM Income Tax Officer-25(3)(3) Rajen Nanalal Shanghvi Room No. 233, 2nd Floor, B-701, Swapnalok, Kautilya Bhawan, Vs. Dixit Road, Vile Parle (E), Bandra Kurla Complex, Mumbai-400 057 Bandra (E), Mumbai-400 051 PAN/GIR No. AAEPS 4098 N (Appellant) (Respondent) : Appellant by : Shri Bharat Andhle Respondent by : Ms. Kinjal Bhuta Date of Hearing : 09.03.2021 : 09.03.2021 Date of Pronouncement O R D E R Per Shamim Yahya, A. M.: This appeal by the Revenue is directed against the order of the learned Commissione…