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238 results for “penalty u/s 271”+ Section 26(1)(iii)clear

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Key Topics

Addition to Income73Section 14A71Section 143(3)62Disallowance39Section 153C37Section 10A35Transfer Pricing33Section 14832Section 133A

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

ITA 531/BANG/2024[2014-15]Status: DisposedITAT Bangalore29 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 132Section 153ASection 271(1)(c)

26 of 36 explanation to Section 132 (4), which was inserted by the Direct Tax Laws (Amendment) Act, 1987 w.e.f. 1st April, 1989, further clarifies that a person may be examined not only in respect of the books of accounts or other documents found as a result of search but also in respect of all matters relevant for the purposes

R G PATIL & COMPANY,HAVERI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Showing 1–20 of 238 · Page 1 of 12

...
28
Section 271(1)(c)24
Comparables/TP23
Penalty23

In the result, these 2 appeals of the assessee in ITA Nos

ITA 352/BANG/2021[2010-11]Status: DisposedITAT Bangalore31 May 2022AY 2010-11

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri S.V Ravishankar, AdvocateFor Respondent: Shri Sankar Ganesh K, JCIT (DR)
Section 271(1)(c)

271(1), which provides as follows : "(b) the due date for filing the return of income for such previous year has expired but the assessee has not filed the return ;" 6. The aforesaid clause, we are inclined to think, is not applicable to the case of the assessee for the simple reason that it is not the case

M. VEERABHADRAIAH,BANGALORE vs. ITO, BANGALORE

In the result, the assessee's appeals for A

ITA 345/BANG/2014[2007-08]Status: DisposedITAT Bangalore30 Jan 2015AY 2007-08
For Appellant: Shri K. Venugopala Raju, AdvocateFor Respondent: Dr. P.K. Srihari, Addl. CIT (D.R)
Section 133ASection 139(1)Section 139(4)Section 143(3)Section 271(1)(c)Section 274

26 (Bang) dt.22.2.2013 for Assessment Years 2007-08 & 2008-09 and it was therein held that there can be no justification for levy of penalty under Section 271(1)(c) of the Act for concealment of income or furnishing of inaccurate particulars of income by the assessee on the income offered in the return of income for the concerned assessment

M/S TURBOTECH PRECISION ENGINEERING PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-(7)(1), BANGALORE

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

ITA 2252/BANG/2018[2013-14]Status: DisposedITAT Bangalore12 Oct 2018AY 2013-14

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodiaassessment Year : 2013-14

For Appellant: Shri Lokesh Jain, CAFor Respondent: Smt. Sri Nandini Das, JCIT (DR)
Section 271Section 271(1)Section 271(1)(C)Section 274Section 36(1)(iii)

section 36(1)(iii) under the claim that the borrowed funds where advanced by the Appellant to its wholly owned subsidiaries as the interest free funds. 9. The Ld. AO has failed to appreciate the fact that the borrowed funds where directed towards wholly owned subsidiaries of the Appellant as a measure of commercial expediency. The Appellant seeks your leave

M/S. CHILD DEVELOPMENT PROJECT OFFICER,SHIVAMOGGA vs. INCOME-TAX OFFICER, TDS WARD, DAVANGERE

The appeals are partly allowed to the aforesaid extent

ITA 882/BANG/2023[26Q/Quarter-4/2014-15]Status: DisposedITAT Bangalore09 Jan 2024

Bench: Shri George George Kshri Laxmi Prasad Sahu

For Appellant: Shri Hemant Pai, C.AFor Respondent: Shri Nischal B, Addl. CIT (DR)
Section 250

u/s 234E for belatedly filing the TDS return. The Act has been amended from 01/06/2015 and prior to this period, levy of fee was in the statute book, therefore, the assessee is not ITA Nos.882-890/Bang/2023 Page 11 of 17 liable for the period till 01/06/2015 and the issue is squarely covered in favour of the assessee by the decision

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

penalty proceedings initiated under section 274 read with section 271(1)(c) of the Act. Relief 9. On the facts and circumstances of the case and in law, the Appellant prays that the Ld. AO be directed to grant all such relief arising from the preceding grounds as also all relief consequential thereto. 5. Ground Nos.1,2 and 9 (supra

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1448/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

penalty proceedings initiated under section 274 read with section 271(1)(c) of the Act. Relief 9. On the facts and circumstances of the case and in law, the Appellant prays that the Ld. AO be directed to grant all such relief arising from the preceding grounds as also all relief consequential thereto. 5. Ground Nos.1,2 and 9 (supra

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1519/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

penalty proceedings initiated under section 274 read with section 271(1)(c) of the Act. Relief 9. On the facts and circumstances of the case and in law, the Appellant prays that the Ld. AO be directed to grant all such relief arising from the preceding grounds as also all relief consequential thereto. 5. Ground Nos.1,2 and 9 (supra

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1520/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

penalty proceedings initiated under section 274 read with section 271(1)(c) of the Act. Relief 9. On the facts and circumstances of the case and in law, the Appellant prays that the Ld. AO be directed to grant all such relief arising from the preceding grounds as also all relief consequential thereto. 5. Ground Nos.1,2 and 9 (supra

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI CGANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2634/BANG/2018[2010-11]Status: DisposedITAT Bangalore20 Sept 2021AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2637/BANG/2018[2011-12]Status: DisposedITAT Bangalore20 Sept 2021AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2633/BANG/2018[2011-12]Status: DisposedITAT Bangalore20 Sept 2021AY 2011-12

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2636/BANG/2018[2010-11]Status: DisposedITAT Bangalore20 Sept 2021AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2635/BANG/2018[2009-10]Status: DisposedITAT Bangalore20 Sept 2021AY 2009-10

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeals are allowed for statistical purpose

ITA 2631/BANG/2018[2009-10]Status: DisposedITAT Bangalore20 Sept 2021AY 2009-10

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. V. Chandrashekar, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 269SSection 269TSection 271Section 271E

u/s 271E is cash repayments reflected by the assessee himself and it is the failure of the assessee to explain the same satisfactorily which has resulted the Range Head levying the pelanty. The fact of cash advance received, which is in fact admitted by the assessee himself, and application of section 269T 6. For these and such other grounds that

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

ITA 334/BANG/2017[2008-09]Status: DisposedITAT Bangalore10 May 2019AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G. Sitaram, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(iii)

penalty proceedings u/s 271(1)(c) are initiated.” 41. Before the CIT(Appeals), the assessee submitted that while computing book profits u/s. 115JB of the Act, a sum of Rs.9,64,74,211 debited in the P& L a/c as impairment of capital advances and that cannot be added to the profit as per profit and loss account prepared

SRI.RATAN BABULAL LATH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

ITA 335/BANG/2017[2009-10]Status: DisposedITAT Bangalore10 May 2019AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G. Sitaram, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(iii)

penalty proceedings u/s 271(1)(c) are initiated.” 41. Before the CIT(Appeals), the assessee submitted that while computing book profits u/s. 115JB of the Act, a sum of Rs.9,64,74,211 debited in the P& L a/c as impairment of capital advances and that cannot be added to the profit as per profit and loss account prepared

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

ITA 333/BANG/2017[2007-2008]Status: DisposedITAT Bangalore10 May 2019AY 2007-2008

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G. Sitaram, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(iii)

penalty proceedings u/s 271(1)(c) are initiated.” 41. Before the CIT(Appeals), the assessee submitted that while computing book profits u/s. 115JB of the Act, a sum of Rs.9,64,74,211 debited in the P& L a/c as impairment of capital advances and that cannot be added to the profit as per profit and loss account prepared

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

ITA 338/BANG/2017[2012-13]Status: DisposedITAT Bangalore10 May 2019AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G. Sitaram, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(iii)

penalty proceedings u/s 271(1)(c) are initiated.” 41. Before the CIT(Appeals), the assessee submitted that while computing book profits u/s. 115JB of the Act, a sum of Rs.9,64,74,211 debited in the P& L a/c as impairment of capital advances and that cannot be added to the profit as per profit and loss account prepared

M/S.GOLFLINKS SOFTWARE PARK (P) LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeal of the revenue in ITA No

ITA 336/BANG/2017[2010-11]Status: DisposedITAT Bangalore10 May 2019AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G. Sitaram, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 28Section 36(1)(iii)

penalty proceedings u/s 271(1)(c) are initiated.” 41. Before the CIT(Appeals), the assessee submitted that while computing book profits u/s. 115JB of the Act, a sum of Rs.9,64,74,211 debited in the P& L a/c as impairment of capital advances and that cannot be added to the profit as per profit and loss account prepared