JYOTI MEDISERVICES PRIVATE LIMITED,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, ALLAHABAD, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

penalty proceedings against the Appellant under Section 271(1)(c) and 271(1)(b) of the Act.” I.T.A. No.129/Alld/2025 (A.Y. 2012-13 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 6 (A.1) For the sake of convenience, these appeals are hereby disposed of through this consolidated order. At the time of hearing before

JYOTI MEDISERVICES PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

penalty proceedings against the Appellant under Section 271(1)(c) and 271(1)(b) of the Act.” I.T.A. No.129/Alld/2025 (A.Y. 2012-13 I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 6 (A.1) For the sake of convenience, these appeals are hereby disposed of through this consolidated order. At the time of hearing before

AJIT TRIPATHI,ALLAHABAD vs. CIT (A), DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Vijay Pal Raoassessment Year: 2017-18 Ajit Tripathi, V. Income Tax Officer, Village Pandor, Jasra, Ward-1(1), Allahabad Allahabad, U.P. Pan:Aknpt9902B (Appellant) (Respondent) Appellant By: Shri. S.K. Yogeshwar, Adv Respondent By: Shri A. K. Singh, Sr. D.R. Date Of Hearing: 14 02 2023 Date Of Pronouncement: 16 02 2023 O R D E R

14 02 2023 Date of pronouncement: 16 02 2023 O R D E R VIJAY PAL RAO, J.M.: This appeal by the assessee is directed against the order dated 31.10.2022 of the ld. CIT(A), NFAC, New Delhi arising from penalty order passed under section 271A of the Income Tax Act for the Assessment Year 2017-18. 2. The assessee

NEERAJ AGRAWAL,,MIRZAPUR vs. DCIT, MIRZAPUR

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

Penalty proceedings u/s 271(1)(c) is being initiated separately for concealment of income. Addition of Rs. 78,059/-/” 4c. The AO further observed that there are cash deposits recorded in the cash books maintained by the assessee, which were found during the course of survey operations u/s 133A on 24.02.2012, as detailed hereunder: S.No. Date Concerned Perons/Firm name Amount

DCIT CIRCLE-3, MIRZAPUR vs. SHRI NEERAJ AGRAWAL, MIRZAPUR

Bench: Shrivijay Pal Rao & Shri Ramit Kochar

Penalty proceedings u/s 271(1)(c) is being initiated separately for concealment of income. Addition of Rs. 78,059/-/” 4c. The AO further observed that there are cash deposits recorded in the cash books maintained by the assessee, which were found during the course of survey operations u/s 133A on 24.02.2012, as detailed hereunder: S.No. Date Concerned Perons/Firm name Amount

DILSHAD HUSAIN,ALLAHABAD vs. ACIT CIRCLE-1, ALLAHABAD

In the result, the appeal of the assessee in ITA Nos

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.52, 53 & 54/Alld/2024 A.Ys. 2009-10 & 2011-12 Dilshad Husain, Cit(Appeal), National 178, Salreha Pacchim, Sirathu, Vs. Faceless Appeal Centre Allahabad, U.P. Pan:Acbph7430G (Appellant) (Respondent)

section 271(1)(c). This penalty order was also passed ex parte and was subsequently dismissed by the first appellate authority. The assessee subsequently filed appeals against the summary dismissal of his appeals and the Hon’ble ITAT observed, that the ld. CIT(A) had dismissed the appeal without giving sufficient opportunity to the assessee. Therefore, in the interest

DILSHAD HUSAIN,ALLAHABAD vs. ITO- 2(1), ALLAHABAD

In the result, the appeal of the assessee in ITA Nos

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.52, 53 & 54/Alld/2024 A.Ys. 2009-10 & 2011-12 Dilshad Husain, Cit(Appeal), National 178, Salreha Pacchim, Sirathu, Vs. Faceless Appeal Centre Allahabad, U.P. Pan:Acbph7430G (Appellant) (Respondent)

section 271(1)(c). This penalty order was also passed ex parte and was subsequently dismissed by the first appellate authority. The assessee subsequently filed appeals against the summary dismissal of his appeals and the Hon’ble ITAT observed, that the ld. CIT(A) had dismissed the appeal without giving sufficient opportunity to the assessee. Therefore, in the interest

DILSHAD HUSAIN,ALLAHABAD vs. ACIT CIR.-1, ALLAHABAD

In the result, the appeal of the assessee in ITA Nos

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharyita Nos.52, 53 & 54/Alld/2024 A.Ys. 2009-10 & 2011-12 Dilshad Husain, Cit(Appeal), National 178, Salreha Pacchim, Sirathu, Vs. Faceless Appeal Centre Allahabad, U.P. Pan:Acbph7430G (Appellant) (Respondent)

section 271(1)(c). This penalty order was also passed ex parte and was subsequently dismissed by the first appellate authority. The assessee subsequently filed appeals against the summary dismissal of his appeals and the Hon’ble ITAT observed, that the ld. CIT(A) had dismissed the appeal without giving sufficient opportunity to the assessee. Therefore, in the interest

CHANDRA BHAWAN,KAUSHAMBI vs. ADDL./JOINT/ACIT/ITO, NFAC, DELHI

In the result, while appeal in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Chandra Bhawan, Vs. Additional/Joint/Deputy/Assis Chak Guraini, Baish Kanti, Kaushambi- Tant Commissioner Of Income 212206 Tax/Income-Tax Officer, Present Address National Faceless Assessment 39A/L/2, Om Prakash, Sabhasad Marg, Centre, Delhi Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) A.Y. 2016-17 Chandra Bhawan, Vs. Income Tax Officer, Chak Guraini, Baish Kanti, Kaushambi- Ward-2(5), Kaushambi 212206 Present Address 39A/L/2, Om Prakash, Sabhasad Marg, Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) Assessee By: Sh. Mayank Arora, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 19.01.2024 (For The Assessment

14. Because the order passed U/s 147 r.w.s 144 r.w.s 144B by the Ld. Assessing Authority and the order passed U/s 250 by the Ld. First Appellate Authority is bad in law and against the facts.” 3. The facts of the case are that the assessee filed a return of income for the A.Y. 2016-17 on 2.03.2017, declaring total

CHANDRA BHAWAN,KAUSHAMBI vs. ITO WARD-2(5), , KAUSHAMBI

In the result, while appeal in ITA No

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Chandra Bhawan, Vs. Additional/Joint/Deputy/Assis Chak Guraini, Baish Kanti, Kaushambi- Tant Commissioner Of Income 212206 Tax/Income-Tax Officer, Present Address National Faceless Assessment 39A/L/2, Om Prakash, Sabhasad Marg, Centre, Delhi Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) A.Y. 2016-17 Chandra Bhawan, Vs. Income Tax Officer, Chak Guraini, Baish Kanti, Kaushambi- Ward-2(5), Kaushambi 212206 Present Address 39A/L/2, Om Prakash, Sabhasad Marg, Kalindipuram, Prayagraj-211011 Pan:Ahjpb4378C (Appellant) (Respondent) Assessee By: Sh. Mayank Arora, Advocate Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 14.11.2024 Date Of Pronouncement: 29.11.2024 O R D E R Per Nikhil Choudhary, A.M.: These Two Appeals Have Been Filed Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961 On 19.01.2024 (For The Assessment

14. Because the order passed U/s 147 r.w.s 144 r.w.s 144B by the Ld. Assessing Authority and the order passed U/s 250 by the Ld. First Appellate Authority is bad in law and against the facts.” 3. The facts of the case are that the assessee filed a return of income for the A.Y. 2016-17 on 2.03.2017, declaring total

ARPIT HOSPITAL PRIVATE LIMITED,,ALLAHABAD vs. DCIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX(CENTRAL CIRCLE), ALLAHABAD vs. JEEVAN JYOTI CHARITABLE TRUST, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

VANDANA BANSAL L/H OF LATE DR. ASHWANI KUMAR BANSAL, ,ALLAHABAD vs. ACIT, CENTRAL CIRCLE,, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237

DEPUTY COMMISSIONER OF INCOME TAX, ALLAHABAD vs. NAVJEEVAN PEDIATRICS PRIVATE LIMITED, ALLAHABAD

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

271 ITR 401 (SC) for the proposition that rule of construction is to be applied only when there is an ambiguity. Learned Departmental Representatives also relied on orders of Mumbai Bench of ITAT in the cases of Pratibha Pipes & Structurals Ltd. vs. DCIT 173 taxmann.com 147 (Mumbai-Trib) and Usha Satish Salvi vs. ACIT (order dated 23/10/2025 in I.T.A. Nos.4237