Patan Nagrik Sahakari Bank Ltd. v. DIT (CIB)

338 ITR 167High Court#11518 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2023 to 2023.

Judgments citing Patan Nagrik Sahakari Bank Ltd. v. DIT (CIB)

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 271/BANG/2023[2014-15]Status: DisposedITAT Bangalore24 May 2023AY 2014-15

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 270/BANG/2023[2013-14]Status: DisposedITAT Bangalore24 May 2023AY 2013-14

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 269/BANG/2023[2012-13]Status: DisposedITAT Bangalore24 May 2023AY 2012-13

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 268/BANG/2023[2011-12]Status: DisposedITAT Bangalore24 May 2023AY 2011-12

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 267/BANG/2023[2010-11]Status: DisposedITAT Bangalore24 May 2023AY 2010-11

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 266/BANG/2023[2009-10]Status: DisposedITAT Bangalore24 May 2023AY 2009-10

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 265/BANG/2023[2008-09]Status: DisposedITAT Bangalore24 May 2023AY 2008-09

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 264/BANG/2023[2007-08]Status: DisposedITAT Bangalore24 May 2023AY 2007-08

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

M/S. Suco Souharda Sahakari Bank Ltd., Bellary vs. The Joint Director of Income Tax(Intelligence & Criminal Investigation), Bengaluru

In the result, appeals of the assessee are allowed

ITA 263/BANG/2023[2006-07]Status: DisposedITAT Bangalore24 May 2023AY 2006-07

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. V. Srinivasan, Advocate and Ms. Sunaina Bhatia, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 133ASection 250Section 271BSection 271FSection 285BSection 51

…d that for imposing penalty under section 271FA of the Act, the AO and CIT(A) had strongly placed reliance on ITA Nos.263 to 271/Bang/2023 Page 10 of 11 the judgment of Hon’ble Gujarat High Court in the case of Patan Nagrik Sahakari Bank Ltd., Vs. DIT (CIB) 338 ITR 167 (Gujarat). The judgment of the Hon’ble Gujarat High Court is distinguishable on the facts due to the following reasons: i) The Hon'ble High Court has rendered the judgement on 4th March, 2011 and thus, there was no occasion for the Hon'ble High Court to consider the subsequent substitution of the Rule 114E of the I.T. Rules with effect from 01/0…

Patan Nagrik Sahakari Bank Ltd. v. DIT (CIB) (338 ITR 167) — Cited in 9 Judgments | BharatTax