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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

41. Accordingly, in view of the above facts, wherein similar additions with respect to the same piece of land has been deleted in the hands of co-owner of the said property and the consequential penalty was also deleted by ITAT, vide order dated 17.09.2021, we are of the considered view that penalty under Section 271

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)

41,92,634/- on which penalty was levied by TPO and ALP is determined at the value declared by the assessee. He further submitted that AO has levied penalty u/s 271AA on the ground that assessee had failed to report The interactional Transactions and had initialed the penalty by invoking Clause (ii) and (m) of Section 271AA

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)

41,92,634/- on which penalty was levied by TPO and ALP is determined at the value declared by the assessee. He further submitted that AO has levied penalty u/s 271AA on the ground that assessee had failed to report The interactional Transactions and had initialed the penalty by invoking Clause (ii) and (m) of Section 271AA

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)

41,92,634/- on which penalty was levied by TPO and ALP is determined at the value declared by the assessee. He further submitted that AO has levied penalty u/s 271AA on the ground that assessee had failed to report The interactional Transactions and had initialed the penalty by invoking Clause (ii) and (m) of Section 271AA

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)

41,92,634/- on which penalty was levied by TPO and ALP is determined at the value declared by the assessee. He further submitted that AO has levied penalty u/s 271AA on the ground that assessee had failed to report The interactional Transactions and had initialed the penalty by invoking Clause (ii) and (m) of Section 271AA

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)

41,92,634/- on which penalty was levied by TPO and ALP is determined at the value declared by the assessee. He further submitted that AO has levied penalty u/s 271AA on the ground that assessee had failed to report The interactional Transactions and had initialed the penalty by invoking Clause (ii) and (m) of Section 271AA

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

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

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

41 ITR 425 and CIT v. Bheekha Bhai Dada Bhai [1961] 42 ITR 123 has held that the assessment does not mean only computation of income but consideration of all facts including the liability for penalty that may attract the provisions contained in section 271(1)(a) of the Act. It has further held that if in any proceeding

M/S. WORLD TRADE IMPEX LTD.,,BARODA vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, CIRCLE-5,, BARODA

In the result, the appeal of the assessee is hereby allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

u/s 271(1)(c). 38. Being aggrieved by the order of the learned CIT(A), the assessee is in appeal before us. 39. The learned AR before us submitted that the assessee has neither furnished inaccurate particulars of income nor concealed the particulars of income. Therefore, there cannot be levied any penalty under the provisions of section 271

WORLD TRADE IMPEX LTD.,,BARODA vs. THE ACIT.,CIRCLE-4,, BARODA

In the result, the appeal of the assessee is hereby allowed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

u/s 271(1)(c). 38. Being aggrieved by the order of the learned CIT(A), the assessee is in appeal before us. 39. The learned AR before us submitted that the assessee has neither furnished inaccurate particulars of income nor concealed the particulars of income. Therefore, there cannot be levied any penalty under the provisions of section 271

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\nAnd Shri Narendra Prasad Sinha (Accountant Member)

41,92,634/- on\nwhich penalty was levied by TPO and ALP is determined at the\nvalue declared by the assessee. He further submitted that AO\nhas levied penalty u/s 271AA on the ground that assessee had\nfailed to report The interactional Transactions and had initialed\nthe penalty by invoking Clause (ii) and (m) of Section 271AA of\nthe

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\nAnd Shri Narendra Prasad Sinha (Accountant Member)

41,92,634/- on\nwhich penalty was levied by TPO and ALP is determined at the\nvalue declared by the assessee. He further submitted that AO\nhas levied penalty u/s 271AA on the ground that assessee had\nfailed to report The interactional Transactions and had initialed\nthe penalty by invoking Clause (ii) and (m) of Section 271AA of\nthe

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271