PCIT v. Neeraj Jindal

393 ITR 1High Court2017#631 most cited

What is PCIT v. Neeraj Jindal authority for?

If an assessment under Section 148/147 is accepted without modification or addition, or if an amount is surrendered in a return filed under Section 153A, no penalty under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income can be imposed.

156

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

PCIT v. Neeraj Jindal · 393 ITR 1 · Section 271(1)(c) penalty · concealment of income · furnishing inaccurate particulars · Section 153A assessment · surrender of income · Section 148 reassessment · assessment accepted without modification

Also reported as

79 Taxmann.com 96

Sections most often in play

Section 153ASection 271(1)(c)Section 139(1)Section 143(3)Section 148Section 147Section 132Section 274

Issues it is cited on

section 90(3)section 65(b)section 276section 80hhc(3)section 65b(4)section 163section 153b(1)section 42azadi bachao andolanhouse property incomesection 115japenalty under section 271(1)(c)

Judgments citing PCIT v. Neeraj Jindal

ABCI INFRASTRUCTURES PVT. LTD.,KOLKATA, WEST BENGAL vs. ACIT/DCIT, CENTRAL CIRCLE 1, GUWAHATI, GUWAHATI, ASSAM

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

ITA 419/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL, GAUHATI BENCH, GUWAHATI BEFORE SHRI DUVVURU RL REDDY, VICE PRESIDENT AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER ITA No. 418 & 419/GTY/2025 (Assessment Years: 2015-16 & 2016-17) ABCI Infrastructures Pvt. Ltd., ACIT/DCIT, 2/7, Sarat Bose Road, 6th Floor, Central Circle-1, Vs. Bhowanipore, Kolkata-700020 Guwahati. (West Bengal) PAN No. AACCM 3317 R Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri S.K. Tulsiyan, Advocate Department represented by Shri Santosh Kumar Karnani, Addl.CIT Date of hearing 09/03/2026 Date of pronouncement 13/03/2026 O R D E R PER: BE…

ABCI INFRASTRUCTURES PVT. LTD.,KOLKATA, WEST BENGAL vs. ACIT/DCIT, CENTRAL CIRCLE 1, GUWAHATI, GUWAHATI, ASSAM

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

ITA 418/GTY/2025[2015-16]Status: DisposedITAT Guwahati13 Mar 2026AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

Section 132(1)Section 139(1)Section 153ASection 250Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL, GAUHATI BENCH, GUWAHATI BEFORE SHRI DUVVURU RL REDDY, VICE PRESIDENT AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER ITA No. 418 & 419/GTY/2025 (Assessment Years: 2015-16 & 2016-17) ABCI Infrastructures Pvt. Ltd., ACIT/DCIT, 2/7, Sarat Bose Road, 6th Floor, Central Circle-1, Vs. Bhowanipore, Kolkata-700020 Guwahati. (West Bengal) PAN No. AACCM 3317 R Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri S.K. Tulsiyan, Advocate Department represented by Shri Santosh Kumar Karnani, Addl.CIT Date of hearing 09/03/2026 Date of pronouncement 13/03/2026 O R D E R PER: BE…

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

ITA 160/ASR/2023[2015-16]Status: DisposedITAT Amritsar20 Jan 2026AY 2015-16

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

For Appellant: Sh. Devang Gargieya (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 1Section 139Section 148Section 153ASection 271(1)(c)Section 273B

…losure is accepted by the revenue without any change then no case of penalty u/s 271(1)(c) could be made out against the assessee. The case of the assessee is also supported by the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. Neeraj Jindal (393 ITR 1) wherein it was held that when AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed u/s 153A. Once the AO accep…

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

ITA 159/ASR/2023[2014-15]Status: DisposedITAT Amritsar20 Jan 2026AY 2014-15

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

For Appellant: Sh. Devang Gargieya (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 1Section 139Section 148Section 153ASection 271(1)(c)Section 273B

…losure is accepted by the revenue without any change then no case of penalty u/s 271(1)(c) could be made out against the assessee. The case of the assessee is also supported by the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. Neeraj Jindal (393 ITR 1) wherein it was held that when AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed u/s 153A. Once the AO accep…

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

ITA 158/ASR/2023[2013-14]Status: DisposedITAT Amritsar20 Jan 2026AY 2013-14

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

For Appellant: Sh. Devang Gargieya (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 1Section 139Section 148Section 153ASection 271(1)(c)Section 273B

…losure is accepted by the revenue without any change then no case of penalty u/s 271(1)(c) could be made out against the assessee. The case of the assessee is also supported by the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. Neeraj Jindal (393 ITR 1) wherein it was held that when AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed u/s 153A. Once the AO accep…

HIMANI GOYA SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

ITA 157/ASR/2023[2012-13]Status: DisposedITAT Amritsar20 Jan 2026AY 2012-13

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

For Appellant: Sh. Devang Gargieya (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 1Section 139Section 148Section 153ASection 271(1)(c)Section 273B

…losure is accepted by the revenue without any change then no case of penalty u/s 271(1)(c) could be made out against the assessee. The case of the assessee is also supported by the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. Neeraj Jindal (393 ITR 1) wherein it was held that when AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed u/s 153A. Once the AO accep…

HIMANI GOYAL SHARMA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, BATHINDA

The appeal stand allowed

ITA 156/ASR/2023[2011-12]Status: DisposedITAT Amritsar20 Jan 2026AY 2011-12

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DAS GUPTA (Judicial Member)

For Appellant: Sh. Devang Gargieya (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR
Section 1Section 139Section 148Section 153ASection 271(1)(c)Section 273B

…losure is accepted by the revenue without any change then no case of penalty u/s 271(1)(c) could be made out against the assessee. The case of the assessee is also supported by the decision of Hon’ble Delhi High Court in the case of Pr. CIT vs. Neeraj Jindal (393 ITR 1) wherein it was held that when AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed u/s 153A. Once the AO accep…

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…er disallowing the exemption, penalty cannot be imposed. The penalty levied stands set aside." The situation in the present case is still better as no fault has been found with the particulars submitted by the assessee in its Return." [Emphasis supplied] iv) 393 ITR 1 (Del) Pr. CIT v. Neeraj Jindal v) 348 ITR 306 (SC) Price Waterhouse Coopers (P) Ltd. v. CIT vi) 292 ITR 11 (SC) T.Ashok Pai v. CIT 16. The term 'inaccurate particulars' is not defined. Furnishing of an assessment of value of the property may not by itself be furnishing of inaccurate particulars. Even if the Explanations are taken recourse to, a fi…

RAJENDRA CHANDRAKANT CHINCHNIKAR,PUNE vs. CIT(A)-11, PUNE

In the result, the appeal filed by the assessee is dismissed

ITA 1700/PUN/2025[2019-20]Status: DisposedITAT Pune29 Sept 2025AY 2019-20

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Pandaassessment Year : 2019-20 Rajendra Chandrakant Chinchnikar Acit, Central Circle, 2165, B Ward, Koshti Galli, Vs. Kolhapur Mangalwar Peth, Pune – 416012 Pan: Acppc3559D (Appellant) (Respondent) Assessee By : Shri Tanzil Padvekar Department By : Shri Milind Debaje, Jcit Date Of Hearing : 25-08-2025 Date Of Pronouncement : 29-09-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Tanzil PadvekarFor Respondent: Shri Milind Debaje, JCIT
Section 133ASection 139(5)Section 143(1)(a)Section 143(2)Section 270ASection 270A(2)(a)Section 270A(9)(e)Section 274Section 69A

…f the Act for mis-reporting does not arise and therefore, the order of the Ld. CIT(A) levying the penalty of Rs.35,92,000/- u/s 270A should be deleted. 11. Referring to the decision of the Hon’ble Delhi High Court in the case of PCIT vs. Neeraj Jindal (2017) 393 ITR 1 (Del), he submitted that the Hon’ble High Court in the said decision has held that when an assessee has filed revised return after search has been conducted, and such revised return has been accepted by the Assessing Officer, then merely by virtue of the fact that such return showed a higher income, penalty under section 271(1)(c) cannot be automat…

ASSISTANT COMMISSIONER OF INCOME TA , JAIPUR vs. SHRI NATH CORPORATION, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

…ax return and offered the surrendered amount for the purposes of tax.\nThe appellant has also relied upon the judgement of Hon'ble Delhi High Court in the case of Principal Commissioner of Income-tax-19 v. Neeraj Jindal [2017] 79 taxmann.com 96 (Delhi)/[2017) 393 ITR 1 (Delhi)/[2017] 293 CTR 298 (Delhi)[09-02-2017]. It is held by the Hon'ble Delhi High Court in this case as under:-\n\"20. Therefore, the position that emerges from the above-mentioned provision is that once the assessee files a revised return under Section 153A, for all other provisions of the Act, the revised return will be treated as the original…

ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR vs. JITENDRA KUMAR AGARWAL, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a
Section 133ASection 271(1)(c)

…tax return and offered the surrendered amount for the purposes of tax. The appellant has also relied upon the judgement of Hon'ble Delhi High Court in the case of Principal Commissioner of Income-tax-19 v. Neeraj Jindal [2017] 79 taxmann.com 96 (Delhi)/[2017) 393 ITR 1 (Delhi)/[2017] 293 CTR 298 (Delhi)[09-02-2017]. It is held by the Hon'ble Delhi High Court in this case as under:- "20. Therefore, the position that emerges from the above-mentioned provision is that once the assessee files a revised return under Section 153A, for all other provisions of the Act, the revised return will be treated as the original r…

ASSISTANT COMMISSIONER OF INCOME-TAX, JAIPUR vs. ROYAL JEWELLERS, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

…return\nand offered the surrendered amount for the purposes of tax.\nThe appellant has also relied upon the judgement of Hon'ble Delhi High Court in\nthe case of Principal Commissioner of Income-tax-19 v. Neeraj Jindal [2017] 79\ntaxmann.com 96 (Delhi)/[2017) 393 ITR 1 (Delhi)/[2017] 293 CTR 298\n(Delhi)[09-02-2017]. It is held by the Hon'ble Delhi High Court in this case as\nunder:-\n\"20. Therefore, the position that emerges from the above-mentioned provision is\nthat once the assessee files a revised return under Section 153A, for all other\nprovisions of the Act, the revised return will be treated as the orig…

SANJEEV KUMAR,BULANDSHAHR vs. ACIT, CENTRAL CIRCLE- 14, NEW DELHI

In the result, the Appeal filed by the Assessee stands allowed

ITA 9328/DEL/2019[2013-14]Status: DisposedITAT Delhi22 Aug 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman, Accoutant Member A.Yr. : 2013-14 Sanjeev Kumar, Vs. Acit, Cc-14, New Delhi 77-78, Rama Royal Residency, Milk Mohsangarh, Siyana Road, Bulandshahr, Uttar Pradesh-203001 (Pan: Abbpk0132H) (Appellant) (Respondent)

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Amisha Gupt, CIT(DR)
Section 139Section 153ASection 271(1)(c)Section 271A

…ed qua the amount of Rs. 92,00,000/- (wrongly mentioned by the CIT(A) as Rs. 98,20,000/-) which was surrendered in the return of income of Assessment Year 2013-14 filed u/s. 153A, in view of the settled law decided in the case of PCIT vs. Neeraj Jindal (2017) 393 ITR 1 (Del. HC). In any case, Ld. CIT(A) could have initiated penalty and could not have imposed this penalty u/s. 271(1)(c) when it was not initiated by AO as AO initiated penalty proceedings u/s. 271AAB in respect of this sum of 2 Rs. 92,00,000/- as per assessment order and imposed penalty u/s. 271AAB on this sum which was deleted by the CIT(A). It is…

KHODIYAR ORGANISERS, SURAT,SURAT vs. ACIT, CIRCLE-2(3), SURAT, SURAT

In the result, the appeal of the assessee is allowed

ITA 36/SRT/2024[2015-16]Status: DisposedITAT Surat13 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.36/Srt/2024 Assessment Year: (2015-16) (Hybrid Hearing) M/S Khodiyar Organisers, Vs. Acit, Central Plaza, Near Om Terrace, Circle – 2(3), New City Light Road, Surat – Surat 395007, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakfk1498A (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 21/07/2025 Date Of Pronouncement 13/08/2025

Section 133ASection 139(5)Section 143(2)Section 250Section 271(1)(c)

…IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.36/SRT/2024 Assessment Year: (2015-16) (Hybrid hearing) M/s Khodiyar Organisers, Vs. ACIT, Central Plaza, Near Om Terrace, Circle – 2(3), New City Light Road, Surat – Surat 395007, Gujarat "थायीलेखासं./जीआइआरसं./PAN/GIR No: AAKFK1498A (Appellant) (Respondent) Appellant by Shri P. M. Jagasheth, CA Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 21/07/2025 Date of Pronouncement 13/08/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM: This ap…

SURESH KUMAR MISHRA,NEW DELHI vs. ACIT, CC-25, NEW DELHI

The appeal of the assessee is dismissed

ITA 1769/DEL/2021[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Manish Agarwalsuresh Kumar Mishra Vs. Acit, Cc-25 24 Lok Vihar Apartment Jhandwal Extension Vikas Puri, New Delhi – 110055 Delhi – 110018 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aalpm2008D Appellant .. Respondent

For Appellant: Sh. Salil Aggrawal, Sr. Adv &For Respondent: Ms. Amisha S. Gupt, CIT, (DR)
Section 115BSection 132Section 132(4)Section 139Section 153Section 153ASection 69

…he same accordingly. 8.5 The Honble High Court of Bombay in the case of Principal Commissioner of Income -tax, Central-2 vs JSW Steel Ltd, 422 ITR 71 and the Honble High Court of Delhi in the case of Principal Commissioner of Income -tax-19 vs Neeraj Jindal, 393 ITR 1, have pronounced judgements on the issue, as discussed in above paras. 8.6 Thus, Section 153A provides the procedure for completion of assessment where a search is initiated under Section 132 or books of account, or other documents or any assets are requisitioned under Section 132A after 31.05.2003. In such cases, the Assessing Officer shall issue…

KRISHNAPPA GOWDER KALYANASUNDARAM,COIMBATORE vs. DCIT, CC-3,, COIMBATORE

The appeal stand allowed accordingly

ITA 1905/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 May 2025AY 2014-15

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri N. Arjun Raj (Advocate) – Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -
Section 139Section 139(1)Section 153ASection 153A(1)Section 271(1)(c)Section 40A

…me is voluntarily admitted in the return of income filed u/s 153A. On these facts, in our considered opinion, no case of concealment of income could be made out against the assessee as per the decision of Hon’ble Delhi High Court in the case of Neeraj Jindal (79 Taxmann.com 96). The Hon’ble Court, in para-21 of the decision, held that when Ld. AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at…

KRISHNAPPA GOWDER KALYANASUNDARAM,COIMBATORE vs. DCIT, CENTRAL CIRCLE-4,, COIMBATORE

The appeal stand allowed accordingly

ITA 1904/CHNY/2024[2013-14]Status: DisposedITAT Chennai21 May 2025AY 2013-14

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri N. Arjun Raj (Advocate) – Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -
Section 139Section 139(1)Section 153ASection 153A(1)Section 271(1)(c)Section 40A

…me is voluntarily admitted in the return of income filed u/s 153A. On these facts, in our considered opinion, no case of concealment of income could be made out against the assessee as per the decision of Hon’ble Delhi High Court in the case of Neeraj Jindal (79 Taxmann.com 96). The Hon’ble Court, in para-21 of the decision, held that when Ld. AO accepted the revised return filed by the assessee u/s 153A, no occasion arises to refer to the previous return filed u/s 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), KOLKATA, KOLKATA vs. RADHESHYAM AGARWALA, KOLKATA

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2607/KOL/2024[2020-21]Status: DisposedITAT Kolkata20 May 2025AY 2020-21

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

…ed; and (iii) the returns filed in response to the notice u/s.153C of the Act was accepted and as the returns u/s.153C of the Act have been accepted in view of the decisions of the Hon’ble Delhi High Court in the case of Shri Neeraj Jindal, reported in [2017] 393 ITR 1 (Delhi), the Hon’ble Madras High Court in the case of M. Panchamuthu, reported in [2007] 295 ITR 502 (Mad), the Hon’ble Bombay High Court in the case of B.G.Shirke Construction Technology Pvt. Ltd., reported in [2017] 79 taxmann.com 306 (Bom) and in the case of Orient Press Ltd., reported in [2008] 21 SOT 25, as referred to by the ld. CIT(A), the p…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), KOLKATA, KOLKATA vs. RADHESHYAM AGARWALA, KOLKATA

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2606/KOL/2024[2019-20]Status: DisposedITAT Kolkata20 May 2025AY 2019-20

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

…ed; and (iii) the returns filed in response to the notice u/s.153C of the Act was accepted and as the returns u/s.153C of the Act have been accepted in view of the decisions of the Hon’ble Delhi High Court in the case of Shri Neeraj Jindal, reported in [2017] 393 ITR 1 (Delhi), the Hon’ble Madras High Court in the case of M. Panchamuthu, reported in [2007] 295 ITR 502 (Mad), the Hon’ble Bombay High Court in the case of B.G.Shirke Construction Technology Pvt. Ltd., reported in [2017] 79 taxmann.com 306 (Bom) and in the case of Orient Press Ltd., reported in [2008] 21 SOT 25, as referred to by the ld. CIT(A), the p…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(1), KOLKATA, KOLKATA vs. RADHESHYAM AGARWALA, KOLKATA

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2605/KOL/2024[2018-19]Status: DisposedITAT Kolkata20 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

…ed; and (iii) the returns filed in response to the notice u/s.153C of the Act was accepted and as the returns u/s.153C of the Act have been accepted in view of the decisions of the Hon’ble Delhi High Court in the case of Shri Neeraj Jindal, reported in [2017] 393 ITR 1 (Delhi), the Hon’ble Madras High Court in the case of M. Panchamuthu, reported in [2007] 295 ITR 502 (Mad), the Hon’ble Bombay High Court in the case of B.G.Shirke Construction Technology Pvt. Ltd., reported in [2017] 79 taxmann.com 306 (Bom) and in the case of Orient Press Ltd., reported in [2008] 21 SOT 25, as referred to by the ld. CIT(A), the p…

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