DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

271(1)(c) of the Act was levied on the income offered by revised return after the same was accepted by the assessee in the survey proceedings. 4.1 Accordingly, the AO held that the assessee has concealed the particular of additional income of Rs. 65 lacs offered during the proceedings under section 153A of the Act and levied the penalty

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

section 271(1B). Therefore, in view of the above factual and legal position, I hold that Assessing Officer had recorded his satisfaction as mandated by the law and hence arguments of Ld. Authorized Representative on this account are rejected. 6.2. The appellant has also submitted that while initiating the penalty proceedings, the Assessing Officer has not specified as to whether

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

section 271(1B). Therefore, in view of the above factual and legal position, I hold that Assessing Officer had recorded his satisfaction as mandated by the law and hence arguments of Ld. Authorized Representative on this account are rejected. 6.2. The appellant has also submitted that while initiating the penalty proceedings, the Assessing Officer has not specified as to whether

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

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

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

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

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

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

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

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

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

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

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

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

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

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

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

271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains or furnishes

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

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