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169 results for “penalty u/s 271”+ Section 142(2)(a)clear

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Key Topics

Section 14895Addition to Income86Section 14778Section 271(1)(c)69Section 143(3)57Penalty57Section 142(1)53Section 14A45Section 250

SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

ITA 1872/AHD/2024[2009-10]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2009-10
For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Rignesh Das, CIT DR
Section 143(3)Section 144C(3)Section 271Section 271(1)(c)Section 275Section 92C

u/s 271(l)(c) of Rs. 2,76,33,870.\n9. The learned CIT(A) erred in fact and in law in confirming the action of the\nlearned AO in levying penalty despite the fact that the Appellant has not furnished\ninaccurate particulars of income either in return of income or during the course of\nassessment proceedings.\n10. The learned

Showing 1–20 of 169 · Page 1 of 9

...
41
Section 69A41
Natural Justice27
Reopening of Assessment25

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 319/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2014-15

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the Act. However, on perusal of such penalty order, there is complete lack of satisfaction on part of Assessing Officer to record which were material documents/information which were not provided to the TPO for such purchase transactions. The AO has merely mentioned that appellant has failed to maintain documents specified in Section

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 324/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2019-20

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the Act. However, on perusal of such penalty order, there is complete lack of satisfaction on part of Assessing Officer to record which were material documents/information which were not provided to the TPO for such purchase transactions. The AO has merely mentioned that appellant has failed to maintain documents specified in Section

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 322/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the Act. However, on perusal of such penalty order, there is complete lack of satisfaction on part of Assessing Officer to record which were material documents/information which were not provided to the TPO for such purchase transactions. The AO has merely mentioned that appellant has failed to maintain documents specified in Section

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 323/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2018-19

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the Act. However, on perusal of such penalty order, there is complete lack of satisfaction on part of Assessing Officer to record which were material documents/information which were not provided to the TPO for such purchase transactions. The AO has merely mentioned that appellant has failed to maintain documents specified in Section

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 321/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the Act. However, on perusal of such penalty order, there is complete lack of satisfaction on part of Assessing Officer to record which were material documents/information which were not provided to the TPO for such purchase transactions. The AO has merely mentioned that appellant has failed to maintain documents specified in Section

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

u/s 271(1)(c) of the Act has rendered, the assessment order erroneous in so far as prejudicial to the interest of the Revenue. The relevant finding of the Hon'ble Allahabad High Court is reproduced as under: "5. We have heard Shri A.N. Mahajan, the learned Standing Counsel for the Revenue and Shri Rishi Raj Kapoor, leamed counsel

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 318/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2013-14

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the\nAct. However, on perusal of such penalty order, there is\ncomplete lack of satisfaction on part of Assessing Officer to\nrecord which were material documents/information which\nwere not provided to the TPO for such purchase transactions.\nThe AO has merely mentioned that appellant has failed to\nmaintain documents specified in Section

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

ITA 320/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2015-16

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

142(1) of the\nAct. However, on perusal of such penalty order, there is\ncomplete lack of satisfaction on part of Assessing Officer to\nrecord which were material documents/information which\nwere not provided to the TPO for such purchase transactions.\nThe AO has merely mentioned that appellant has failed to\nmaintain documents specified in Section

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

ITA 2613/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

2. The learned CIT(A) has grossly erred in law and on facts in upholding the learned Assessing Officer's decision in levying penalty of Rs.166,50,03,312/- under section 271(1)(c) of the Act despite the fact that the appellant is eligible for exemption under sections 10(23C)(iiiab) of the Act and 10(23C)(iiiac

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

ITA 2612/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

2. The learned CIT(A) has grossly erred in law and on facts in upholding the learned Assessing Officer's decision in levying penalty of Rs.166,50,03,312/- under section 271(1)(c) of the Act despite the fact that the appellant is eligible for exemption under sections 10(23C)(iiiab) of the Act and 10(23C)(iiiac

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

ITA 2616/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

2. The learned CIT(A) has grossly erred in law and on facts in upholding the learned Assessing Officer's decision in levying penalty of Rs.166,50,03,312/- under section 271(1)(c) of the Act despite the fact that the appellant is eligible for exemption under sections 10(23C)(iiiab) of the Act and 10(23C)(iiiac

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

ITA 2615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

2. The learned CIT(A) has grossly erred in law and on facts in upholding the learned Assessing Officer's decision in levying penalty of Rs.166,50,03,312/- under section 271(1)(c) of the Act despite the fact that the appellant is eligible for exemption under sections 10(23C)(iiiab) of the Act and 10(23C)(iiiac

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

ITA 2614/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

2. The learned CIT(A) has grossly erred in law and on facts in upholding the learned Assessing Officer's decision in levying penalty of Rs.166,50,03,312/- under section 271(1)(c) of the Act despite the fact that the appellant is eligible for exemption under sections 10(23C)(iiiab) of the Act and 10(23C)(iiiac

SUNILKUMAR BHAGCHAND TALREJA,SABARKANTHA vs. THE ITO, WARD-1, HIMATNAGAR

In the result, both the appeals filed by the assessee are allowed

ITA 2107/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad27 Feb 2026AY 2013-14

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 2107 & 2108/Ahd/2025 Assessment Years 2013-14 & 2014-15

For Appellant: Ms. Astha Maniar, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R
Section 115WSection 142Section 142(1)Section 143Section 144Section 148Section 271(1)(b)Section 69C

penalty imposed u/s. 271(1)(b) was specifically to comply with the notice issued under sub- section (2) of section 115WD or under sub-section (2) of section 115WE or under sub-section (1) of section 142

SUNILKUMAR BHAGCHAND TALREJA,SABARKANTHA vs. THE ITO, WARD-1, HIMATNAGAR

In the result, both the appeals filed by the assessee are allowed

ITA 2108/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad27 Feb 2026AY 2014-15

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 2107 & 2108/Ahd/2025 Assessment Years 2013-14 & 2014-15

For Appellant: Ms. Astha Maniar, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R
Section 115WSection 142Section 142(1)Section 143Section 144Section 148Section 271(1)(b)Section 69C

penalty imposed u/s. 271(1)(b) was specifically to comply with the notice issued under sub- section (2) of section 115WD or under sub-section (2) of section 115WE or under sub-section (1) of section 142

VIKAS VIJAY GUPTA,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby\ndismissed

ITA 404/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad27 May 2025AY 2017-18

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No. 404/Ahd/2024\nAssessment Year 2017-18\nVikas Vijay Gupta\nPrincipal Commissioner\n604 Sarap,\nof Income Tax,\nOpp. Navjivan Press Vs Ahmedabad-1,\nP.O. Navjivan,\nAhmedabad\nAhmedabad-380014,\nGujarat\n(Respondent)\nPAN: AEOPG6723L\n(Appellant)\nAssessee Represented: Shri Jaimin Shah, A.R.\nRevenue Represented: Shri R. N. Dsouza, CIT-DR\nDate of hearing : 27-02-2025\nDate of pronouncement : 27-05-2025\nआदे

Section 115BSection 147Section 263Section 271Section 271(1)(c)Section 271ASection 274Section 69A

2. In the present case, it is not in dispute that the LdAO\nconsciously and correctly invoked section 271AAC(1) in the\nreassessment order, but wrongly issued penalty notice\nu/s.271(1)(c) of the Act, which is at best, a procedural defect that\ncould have been rectified by the AO himself invoking section 292B\nof the Act and thereafter

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1278/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad20 Feb 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Pradeep Tulsian, A.RFor Respondent: Shri Ravindra, Sr. D.R
Section 133(6)Section 142(1)Section 148Section 250

142(1) requires clarification of the source of the depositing amount in the bank account of Rs.3613600/-. for the same which is shown in the return of income filed in response to notice u/s 148 of Income Tax Act, 1961. Ld. AO has not consider the reply of the assessee and imposed a penalty u/s 271(l)(b) which

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1277/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad20 Feb 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Pradeep Tulsian, A.RFor Respondent: Shri Ravindra, Sr. D.R
Section 133(6)Section 142(1)Section 148Section 250

142(1) requires clarification of the source of the depositing amount in the bank account of Rs.3613600/-. for the same which is shown in the return of income filed in response to notice u/s 148 of Income Tax Act, 1961. Ld. AO has not consider the reply of the assessee and imposed a penalty u/s 271(l)(b) which

FATEHSINH UDESINH PARMAR,AT. DENA, VADODARA vs. INCOME TAX OFFICER, INCOME TAX OFFICER WARD

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

ITA 772/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad31 May 2024AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year: 2015-16 Fatehsinh Udesinh Parmar, The Income Tax Officer, At. Dena Para, Vs Ward-3(1)(4), Hami Dena Road, Vadodara Vadodara-390022 Gujarat Pan: Awwpp2183 M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Anil B Thakkar, Ar Revenue By : Shri N.J. Vyas, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal Is Filed By The Assessee As Against The Order Dated 4-8-2023 Passed By The Commissioner (Appeals), National Faceless Appeal Centre, Delhi, (Hereinafter Referred To As 'Nfac'), Dismissing The Appeal Against The Order Penalty Passed By The Assessing Officer (Hereinafter Referred As “Ao”) Under Section 271(1)(B) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act') Relating To The Assessment Year (A.Y) 2015-16. Fatehsinh Udesinh Parmar Vs. Ito Asst. Year: 2015-16

For Appellant: Shri Anil B Thakkar, ARFor Respondent: Shri N.J. Vyas, Sr.DR
Section 142(1)Section 144Section 147Section 148Section 271(1)(b)Section 273B

271(1)(b) as why not to levy of penalty for noncompliance of the notices issued under section 142(1) of the Act. Subsequently order u/s 144 r.w.s. 147 was passed by the AO determining total income at Rs. 32,82,480/-. 4. The assessee responded vide reply dated 2