SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE ADIT(EXEMPTION),, AHMEDABAD

In the result, the appeal of the assessee is allowed

269T of the Act, he held that assessee is liable to penalty as contemplated u/s. 271D and 271E of the Act. The penalty was calculated @ 100% of amount so involved for each such infringement. Accordingly, the ld. CIT(A) imposed a penalty of Rs. 95,000 u/s. 271D of the Act and Rs. 4,15,887/- u/s. 271E

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE ADIT(EXEMPTION),, AHMEDABAD

In the result, the appeal of the assessee is allowed

269T of the Act, he held that assessee is liable to penalty as contemplated u/s. 271D and 271E of the Act. The penalty was calculated @ 100% of amount so involved for each such infringement. Accordingly, the ld. CIT(A) imposed a penalty of Rs. 95,000 u/s. 271D of the Act and Rs. 4,15,887/- u/s. 271E

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

269T of the Act, he held that assessee is liable to penalty as contemplated u/s. 271D and 271E of the Act. The penalty was calculated @ 100% of amount so involved for each such infringement. Accordingly, the ld. CIT(A) imposed a penalty of Rs. 95,000 u/s. 271D of the Act and Rs. 4,15,887/- u/s. 271E

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

269T of the Act, he held that assessee is liable to penalty as contemplated u/s. 271D and 271E of the Act. The penalty was calculated @ 100% of amount so involved for each such infringement. Accordingly, the ld. CIT(A) imposed a penalty of Rs. 95,000 u/s. 271D of the Act and Rs. 4,15,887/- u/s. 271E

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

269T of the Act, he held that assessee is liable to penalty as contemplated u/s. 271D and 271E of the Act. The penalty was calculated @ 100% of amount so involved for each such infringement. Accordingly, the ld. CIT(A) imposed a penalty of Rs. 95,000 u/s. 271D of the Act and Rs. 4,15,887/- u/s. 271E

DCIT CIRCLE GANDHINAGAR, GANDHINAGAR vs. SHRI UMIYA CO OPERATIVE CREDIT SOCIETY LTD LINCH, GANDHINAGAR

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271-1], 4[section 271J,] clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 2728 or sub- section (1) or sub-section (1A) of section 272BB or sub-section sub-section (1) of section 2 section 2728BB or clause (b) of sub-section

DCIT, CIRCLE GANDHINAGAR, GANDHINAGAR vs. SHRI UMIYA CO OPERATIVE CREDIT SOCIETY LTD LINCH, GANDHINAGAR

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

271-1], 4[section 271J,] clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 2728 or sub- section (1) or sub-section (1A) of section 272BB or sub-section sub-section (1) of section 2 section 2728BB or clause (b) of sub-section

ATUL N. SHAH,AHMEDABAD vs. THE JT.CIT, RANGE-4(2), AHMEDABAD

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

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita Nos. 952 & 953/Ahd/2023 िनधा"रण वष"/Assessment Year: 2013-14 बनाम बनाम बनाम बनाम Atul N. Shah, 45, Mahalaya Bungalows, Jcit, Vs. Nr. High Court, Sola, Range 4(2), Ahmedabad-380060 Ahmedabad Pan : Ajqps 4627 Q अपीलाथ"/ (Appellant) "त्यथ"/ (Respondent) िनधा" रती की ओर से / Assessee By : Shri Dhrunal Bhatt, Ar "#थ% की ओर से / Revenue By: Shri Atul Pandey, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 29/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 23/08/2024 आदेश आदेश/O R D E R आदेश आदेश

271) held that conclusion as a result of suspicion could not take the place of proof. This principle would apply even in case of penalty proceedings though the decision was rendered in connection with grant of registration to the firm. With Regards to levy of penalty u/s 271E for violation of section 269T

ATUL N. SHAH,AHMEDABAD vs. THE JT.CIT, RANGE-4(2), AHMEDABAD

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

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita Nos. 952 & 953/Ahd/2023 िनधा"रण वष"/Assessment Year: 2013-14 बनाम बनाम बनाम बनाम Atul N. Shah, 45, Mahalaya Bungalows, Jcit, Vs. Nr. High Court, Sola, Range 4(2), Ahmedabad-380060 Ahmedabad Pan : Ajqps 4627 Q अपीलाथ"/ (Appellant) "त्यथ"/ (Respondent) िनधा" रती की ओर से / Assessee By : Shri Dhrunal Bhatt, Ar "#थ% की ओर से / Revenue By: Shri Atul Pandey, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 29/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 23/08/2024 आदेश आदेश/O R D E R आदेश आदेश

271) held that conclusion as a result of suspicion could not take the place of proof. This principle would apply even in case of penalty proceedings though the decision was rendered in connection with grant of registration to the firm. With Regards to levy of penalty u/s 271E for violation of section 269T