“Section 271(1)(a)”

RADHESHYAM AGARWAL,BHOPAL vs. THE PCIT, CENTRAL, BHOPAL , BHOPAL

Tribunal was right in\nrevoking the order of the Addl. Commissioner in so far as it\npertains to the question of penalties under sections 271(1)(a) and\n273(b). Here, we find ourselves in complete agreement with the\nview taken by the Tribunal. It is well established that procecdings ... nfor the levy of a penalty whether under section 271(1)(a) or under\nsection 273(6) are proceedings independent of and separate from\nthe assessment proceedings. Though the expression assessment\"\nis used in the Act with different meanings in different contexts, so\nfar as section 263 is concerned

SATYA VENKATA KRISHNA RAVI PRASAD KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

Court in the\ncase of CIT v. Chennai Metro Rail Ltd., [92 taxmann.com 329 (Madras)\nobserved as follows: -\n“14. In view of Section 271(1) read with Section 263 of the Act, the\nPrincipal Commissioner might pass such order as the circumstances of the\ncase might justify, which could ... Tribunal\nwas right in revoking the order of the Addl. Commissioner in so far as it\npertains to the question of penalties under sections 271(1)(a) and 273(b).\nHere, we find ourselves in complete agreement with the view taken by the\nTribunal. It is well established that proceedings

SATYA VENKATA KRISHNA RAVI PRASAD KODURI,EAST GODHAVARI vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

Court in the\ncase of CIT v. Chennai Metro Rail Ltd., [92 taxmann.com 329 (Madras)\nobserved as follows: -\n“14. In view of Section 271(1) read with Section 263 of the Act, the\nPrincipal Commissioner might pass such order as the circumstances of the\ncase might justify, which could ... Tribunal\nwas right in revoking the order of the Addl. Commissioner in so far as it\npertains to the question of penalties under sections 271(1)(a) and 273(b).\nHere, we find ourselves in complete agreement with the view taken by the\nTribunal. It is well established that proceedings

VEERA VENKATA RAMAKRISHNA MOHAN RAO KODURI,EAST GODHAVARI vs. ACIT, CIRLCE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

High Court in the case of CIT v. Chennai Metro Rail Ltd., [92 taxmann.com 329 (Madras) observed as follows: - “14. In view of Section 271(1) read with Section 263 of the Act, the Principal Commissioner might pass such order as the circumstances of the case might justify, which could ... Tribunal was right in revoking the order of the Addl. Commissioner in so far as it pertains to the question of penalties under sections 271(1)(a) and 273(b). Here, we find ourselves in complete agreement with the view taken by the Tribunal. It is well established that proceedings

VEERA VENKATA RAMAKRISHNA MOHANA RAO KODURI,RAJAHMUNDRY vs. ACIT, CIRCLE - 1, RAJAHMUNDRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita Nos. 290 & 291/Viz/2025 निर्धारण वर्ा/ Assessment Years:2018-19 & 2019-20) Veera Venkata Ramakrishna V. Acit – Circle – 1 Mohana Rao Koduri Ayakkar Bhawan Flat No. 201, Sri Towers Nh-16 Veerabadhrapuram Venkateswara Nagar Rajahmundry – 533105 Syamalanagar Andhra Pradesh East Godavari District - 533103 Andhra Pradesh [Pan:Afrpk0888C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) आईटीए. नं. / Ita Nos. 293 & 294/Viz/2025 निर्धारणवर्ा/ Assessment Years:2018-19 & 2019-20) Satya Venkata Krishna Ravi V. Acit – Circle – 1 Prasad Koduri Ayakkar Bhawan 81-10-3/6, Venkateswaranagar Veerabadhrapuram Near Ima Halla, Danavaipeta Rajahmundry – 533105 East Godavari District Andhra Pradesh Andhra Pradesh [Pan:Afrpk0889D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt Hemalatha K, Ca राजस्व का प्रतततितित्व/ Department Represented By : Shri Badicala Yadagiri, Cit(Dr)

High Court in the case of CIT v. Chennai Metro Rail Ltd., [92 taxmann.com 329 (Madras) observed as follows: - “14. In view of Section 271(1) read with Section 263 of the Act, the Principal Commissioner might pass such order as the circumstances of the case might justify, which could ... Tribunal was right in revoking the order of the Addl. Commissioner in so far as it pertains to the question of penalties under sections 271(1)(a) and 273(b). Here, we find ourselves in complete agreement with the view taken by the Tribunal. It is well established that proceedings

KOTI NARASIMHA REDDY GUTTIKONDA,GUNTUR vs. PRINCIPAL COMMISSIONER OF INCOME TAX , VIJAYAWADA

In the result, appeal of the assessee is allowed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.332/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2016-17) Koti Narasimha Reddy Guttikonda Vs. Pr. Cit 1-99, Rudravaram – 522410 Siddhardha Public School Road Guntur District, Andhra Pradesh Mogalrajapurm Vijayawada – 520010 [Pan: Amcpg7882N] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri K.Siva Ram Kumar, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Ld.Pr.CIT in exercising his powers under section 263 of the Act found that Ld. AO has failed to initiate penalty provisions under section 271(1)(c) of the Act as the assessee concealed his income particulars. Ld.Pr.CIT therefore considered assessment order passed under section 147 r.w.s. 144 r.w.s. 144B ... Appeal.” 5. Assessee has challenged the notice issued under section 148 of the Act and has claimed immunity as per Explanation 4C to section 271(1)(c) of the Act. Ld.AR submitted that the assessee has paid the entire tax on 26.11.2021 whereas notice under section