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penalty proceedings initiated

PenaltySection 271Section 271556 judgments

B R MORDEN SCHOOL,PAURI vs. I T O ,EXEMPTION WARD, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 28/DDN/2026[2017-18]Status: DisposedITAT Dehradun12 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2017-18] B.R. Morden School Samiti Vs Ito Tara Lodge, Exemption, Ward Tehsil Road Pauri, Pauri, Dehradun Uttarakhand-246001. Pan-Aacab6988M Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 05.12.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Against The Penalty Order Dated 21.09.2022 Passed U/S 271B Of The Act Pertaining To Assessment Year 2017-18. 2. Heard The Contentions Of Both Parties & Perused The Material Available On Record. It Is Stated By Ld. Ar That The Quantum Appeal Filed By The Assessee For The Captioned Assessment Year Against The Assessment Order Passed Has Already Been Restored To The File Of Ao By The Tribunal For Passing For Denovo Assessment. Thus, The Current Penalty Proceedings Initiated In The Said Order Has No Legs To Stand. Accordingly, We Delete The Penalty So Levied. The Ao Is At Liberty To Initiate The Proceedings, If The Circumstances Suggests So, In The Set Aside Proceedings In Accordance With Law. With These Directions, Appeal Filed By The Assessee Is Allowed.

Section 250Section 271B

assessment order passed has already been restored to the file of AO by the Tribunal for passing for denovo assessment. Thus, the current penalty proceedings initiated in the said order has no legs to stand. Accordingly, we delete the penalty so levied. The AO is at liberty to initiate

DAWAT E ISLAMI AP,HYDERABAD vs. ITO., EXEMPTION WARD 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1575/HYD/2025[2015-16]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1575/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2015-16) Dawat E Islami Ap, Vs. Income Tax Officer, Hyderabad. Exemption Ward-1(1), Pan: Aabtd5383Q Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Ankit Chokshi, Ca (Hybrid Mode) Assessee Represented By राज"वका""त"न"ध"व/ : Shri Mathivanan S A, Sr. Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 05/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 11/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Dawat E Islami Ap, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 25/07/2025 For The A.Y.2015-16. Dawat E Islami Ap Vs. Ito

Section 12ASection 271(1)Section 271(1)(c)Section 274Section 275

Learned Authorised Representative (“Ld. AR”) submitted that under Ground Nos. 1 and 2, the assessee has challenged the very validity of the penalty proceedings initiated under section 271(1)(c) of the Act. In this regard, the Ld. AR submitted that the notice issued by the Ld. AO under section ... material available on record including the case laws relied upon. The issue raised by the assessee is regarding the validity of the penalty proceedings initiated under section 271(1)(c) of the Act on the basis of the notice issued under section 274 of the Act, wherein

SANTRAM,DEHRADUN vs. ITO WARD 1(1)(3), DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 3/DDN/2026[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2017-18] Santram Vs Ito Near Subhash Chandra Ward-1(1)(3) Bose Academy, Nathuwala, Dehradun Dehradun-248001. Pan-Demps4349P Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 09.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 24.12.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Penalty Order Dated 24.03.2025 Passed U/S 270A Of The Act Pertaining To Assessment Year 2017-18. 2. Heard The Contentions Of Both Parties & Perused The Material Available On Record. It Is Stated By Ld. Ar That The Quantum Appeal Filed By The Assessee For The Captioned Assessment Years Against The Assessment Order Passed Has Already Been Restored Back To The File Of The Ao By The Tribunal Passing For Denovo Assessment Vide Its Order Passed In Ita No.57/Ddn/2025 For Assessment Year 2017-18 Dt. 09.07.2025. Thus, The Current Penalty Proceedings Initiated In The Said Order Has No Legs To Stand. Accordingly, We Delete The Penalty So Levied. The Ao Is At Liberty To Initiate The Proceedings, If Desired, In The Set Aside Proceedings In Accordance With Law. With These Directions, Appeal Filed By The Assessee Is Allowed.

Section 250Section 270A

Tribunal passing for denovo assessment vide its order passed in ITA No.57/DDN/2025 for Assessment Year 2017-18 dt. 09.07.2025. Thus, the current penalty proceedings initiated in the said order has no legs to stand. Accordingly, we delete the penalty so levied. The AO is at liberty to initiate the proceedings

KARUR SREE RAMA TRADING PVT.LTD.,KARUR vs. ITO, CIRCLE-191), TRICHY

In the result, the appeal filed by the assessee is partly allowed

ITA 3841/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3841/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Karur Sree Rama Trading Pvt. Ltd., Vs. The Income Tax Officer, S.F. No. 2262, Pari Nagar, Chinna Circle 1(1), Andan Koil Road, Karur 639 001. Trichy. [Pan:Aabfs8790C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 26.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13 Passed Under Section 147/271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 144Section 147Section 271(1)(c)Section 274

erstwhile partnership firm even though the firm had ceased to 2 I.T.A. No.3841/Chny/25 exist after conversion into a company w.e.f. 02.02.2012 and the penalty proceedings initiated against a non-existent entity are void ab initio. He further submits that the penalty arises from a reassessment order made in the name ... initiating penalty proceedings under section 271(1)(c) of the Act or as per first para of the penalty order dated 31.12.2021, no penalty proceedings initiated in the original assessment order dated 31.03.2015. Under the above facts and circumstances, we quash the order of levying penalty under section

GS & SD ASSOCIATES,CHENNAI vs. ITO, NCW-8(2), CHENNAI

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

ITA 2767/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Feb 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2767/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Gs & Sd Associates, Vs. The Income Tax Officer, No. 03, Vania Street, Kundrathur, Non Corporate Ward 8(2), Chennai 600 069. Chennai. [Pan:Aaqfg8838C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 08.01.2026 घोषणा की तारीख /Date Of Pronouncement 26.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.08.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 6 Grounds Amongst Which The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 68 Of The Income Tax Act , 1961 [“Act” In Short].

For Appellant: Shri Y. Sridhar, CAFor Respondent: Ms. R. Anita, Addl. CIT
Section 142(1)Section 143(2)Section 147Section 148Section 269SSection 68

attention to the order dated 24.06.2020 in the hands of Danasekaran Sambandam passed under section 271D of the Act and argued that the penalty proceedings initiated under section 271D of the Act were dropped by holding that any payment or repayment made pursuant to current account maintained between parties cannot ... assessee as genuine and acceptable and held that it is fair transaction between the assessee and the partners and dropped the penalty proceedings initiated under section 271D of the Act. 8 I.T.A. No.2767/Chny/25 8. We find ledger account of partner capital account of Mr.G. Srinivasan in the books

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