“Section 271(1)”

Income Tax Officer, Mumbai vs. M/S. Amaya Infrastructure Pvt Ltd, Palghar

In the result, the appeal of the Revenue is dismissed

Bench: The Hon’Ble Bombay High Court (Itxal/27362/2024) Against Quantum & The Same Is Pending?”

passed by the National Faceless Appeal Centre, Delhi, whereby the learned Commissioner of Income Tax (Appeals) has deleted the penalty levied under section 271(1)(c) of the Income-tax Act, 1961, for the Assessment Year 2008-09. 2 Amaya Infrastructure Pvt. Ltd. 2. The solitary ground raised ... impugned penalty stood deleted by this Tribunal vide its order dated 10.11.2023. It is equally not in dispute that the penalty under section 271(1)(c) had been levied entirely with reference to the said addition and had no independent or separable basis dehors the quantum proceedings. 4. Once

Amit Kumar Bajaj, Mumbai vs. DCIT-24(1), Mumbai

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

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramit Kumar Bajaj Dcit-24(1), A-3001, Omkar, Off Dr. Piramal Chambers, Annie Besant Road, Near Vs. Lalbaug, Mumbai- Neelam Centre, Hanuman 400 012 Nagar, Worli, Maharashtra – 400 030 Pan/Gir No. Afrpb3442B (Applicant) (Respondent) Assessee By Shri Ravi Ganatra, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 29.01.2026

percent for obtaining the accommodation entry. The reassessment was completed determining total income at Rs. 1,12,80,460/-. Penalty proceedings under section 271(1)(c) were also initiated. 12. Aggrieved by the reassessment order, the assessee preferred an appeal before the CIT(A). The CIT(A) issued several notices

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the ITA Nos. 1936 to 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except

Rajesh B. Jain As Legal Heir of Bhanwarlal M Jain, Mumbai vs. Income Tax Officer, Ward-19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed

Rajesh B. Jain As Legal Heir of Bhanwarlal M Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the ITA Nos. 1936 to 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except

Rajesh B, Jain As Legal of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am Ι.Τ.Α. No.1938/Mum/2024 (Assessment Year: 2008-09) Ι.Τ.Α. No.1937/Mum/2024 (Assessment Year: 2009-10) Ι.Τ.Α. No.1940/Mum/2024 (Assessment Year: 2010-11) Ι.Τ.Α. No.1939/Mum/2024 (Assessment Year: 2011-12) Ι.Τ.Α. No.1941/Mum/2024 (Assessment Year: 2012-13) Ι.Τ.Α. No.1942/Mum/2024 (Assessment Year: 2013-14) Ι.Τ.Α. No.1936/Mum/2024 (Assessment Year: 2014-15) Rajesh B. Jain As Legal Heir Of Bhanwarlal Jain, 171, 17Th Floor, Silver Arch, Petit Hall Compound, Nepeansea Road, Mumbai - 400006 Pan: Aafpj1924R Assessee -अपीलार्थी / Appellant Vs. Ito, Ward-19(1)(1), Piramal Chamber, Lalbaug, Mumbai-400012. Revenue - प्रत्यर्थी / Respondent : Assessee By : Shri Madhur Agarwal, Adv, Shri Fenil Bhat & Shri Sucheck Anchaliya, Ca

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed, thus for the sake of brevity are heard together

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the ITA Nos. 1936 to 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except

Premji Bhurlal Gala, Mumbai vs. Addl CIT Rang 24(1), Mumbai

In the result, Assessee’s appeal is allowed

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Premji Bhurlal Gala Addl. Cit Range 24(1), B-301, Water Ford, Cd Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 To C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 09.12.2025 Date Of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 23.09.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Case Of The Assessee Was Reopened Under Section 147 Of The Act, On The Basis Of Search & Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprises, Wherein The Statement Of The Partner In M/S. Evergreen Enterprises, Mr. Nilesh Bharani Was Recorded Under Section 132(4) Of The Act, Unearthing An Undisclosed Activity, 2 Premji Bhurlal Gala

being unexplained cash loan received from M/s Evergreen Enterprises. 6. The Assessing Officer simultaneously also initiated the penalty proceedings under Sections 271(1)(c), 271 (1)(b), and 271D of the Act. 7. The Assessing Officer in the penalty proceedings u/s 271D of the Act initiated separately, also issued ... assessee bearing ITA 440/Mum/2024, ITA 442/Mum/2024, and ITA 443/Mum/2024 are allowed. 15. Thus, the Assessing Officer, consequently drop the penalty proceedings initiated under Section 271 (1) (c) of the Act, vide order dated 26.02.2025. 16. The ld. Counsel further claimed that in the Assessee’s own case

Shree Krishna Woollen Mills Private Limited, Mumbai vs. DCIT, Mumbai

In the result, the appeal of the assessee is dismissed

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethshree Krishna Woollen Vs. Dcit Circle 15(3)(2), Aayakar Bhawan, Mills Pvt. Ltd. Mumbai-400020. Krishna Mills Compound, L. B.S. Marg, Bhandup West S.O, 400078, Mumbai. Pan/Gir No: Aabcs9353G (Appellant) (Respondent)

under: “1. The Learned Commissioner of Income Tax (Appeals) (CIT) erred in confirming the penalty levied by the Learned AO under section 271 (1) (c) of the Income Tax Act, 1961, being 126% of Tax Payable on total alleged concealed income of Rs.4,88,19,661/-, without duly appreciating ... levy of penalty I have carefully examined the facts of the case, the submissions of the appellant and the penalty order passed under section 271(1)(c) of the Income-tax Act, 1961. I have also perused the appellate orders of the ITA No.6025/MUM/2025/AY 2012-13 Shree Krishna Woollen Mills