SH. MUNISH JAIN,LUDHIANA vs. DCIT, LUDHIANA

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

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

147, 148, 149, 151 and 153 of the Act. The assessee has declared undisclosed income, in the return filed- in response to notice u/s 153A of the Act and the CIT(Appeals), having regard to the facts of the case, invoked the currently applicable Explanation 5A Section 271(1) (c) of the Act and upheld the penalty

SH. MUNISH JAIN,LUDHIANA vs. DCIT, LUDHIANA

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

Bench: Shri Sanjay Garg & Ms. Annapurna Gupta

147, 148, 149, 151 and 153 of the Act. The assessee has declared undisclosed income, in the return filed- in response to notice u/s 153A of the Act and the CIT(Appeals), having regard to the facts of the case, invoked the currently applicable Explanation 5A Section 271(1) (c) of the Act and upheld the penalty

JARNAIL SINGH GILL,JAGRAON vs. INCOME TAX OFFICER, WARD-1, JAGRAON

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

Bench: The Tribunal & The Matter Was Remanded Back To Ao For Fresh Adjudication. Thereafter, The Assessment Order Was Passed

147 r.w.s 254 r.w.s 144B of the Act which means that the subsequent compliance were considered as good compliance by the AO and therefore there is no basis for levy of penalty. It was further submitted that the addition so made in the quantum proceedings have since been deleted by the ld CIT(A) and even on this account

ANJALI SAINI,ZIRAKPUR vs. ITO-WARD-5(5), CHANDIGARH

The appeal of the assesse is allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

u/s 142(1). The copy of the notice under section 142(1) disclosing such remarks have been perused by us from paper book. The remark is dated 22.02.2019. 6. After that a letter dated 05.11.2019 was affixed, again at address #22, Jain Nagar, Amabala, Haryana 133001 even after knowing the fact by the Ld. AO that the assesse has left

SH. PARMINDER SINGH MAVI,MORINDA vs. ITO, ROPAR

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

section 271(1)iii) of the Act and, therefore, upheld the levy of penalty. He further held that the assessee had declared an income only when proceedings u/s 147

SMT. RENU JAIN,ZIRAKPUR vs. ITO-WARD-3(3), CHANDIGARH

Bench: Us:

u/s 271(l)(b) without considering the provisions of s. 273B of the Act and on consideration of provisions of s. 273B, the impugned penalty was not imposable on the appellant. 5. That the appellant craves leave for any addition, deletion or amendment in the grounds of appeal on or before the disposal of the same. 2. Briefly stated, assessment

THE GHARTHOON AGRI CULTURAL SERVICE SOCIETY ,KANGRA, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH , PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271

THE GHARTHOON AGRI CULTURAL SERVICES SOCIETY,KANGRA, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH, PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271

THE GHARTHOON AGRI CULTURAL SERVICES SOCIETY,PALAMPUR, HIMACHAL PRADESH vs. INCOME TAX OFFICER, WARD - PALAMPUR, HIMACHAL PRADESH , PALAMPUR

In the result, appeal is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

147 read with Section 144/144B of the Income Tax Act, ITA No. 927/CHD/2025 emerges out of a penalty proceeding u/s 271

ACIT, CIRCLE, PANCHKULA vs. M/S HIMALAYAN EXPRESSWAY LTD., PINJORE

In the result, appeal of the Revenue is dismissed

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2013-14

section 271(1)(c) which is not correct because the assessee has deliberately furnished the inaccurate particular of its income to evade payment of taxes. 2. It is prayed that the order of the Ld. CIT(A) be set aside and that of the A.O. be restored. 3. Brief facts of the case are that the assessee

SHRI DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

penalty order passed u/s 271(1)(c) vide order dated 25.06.2009 against whom appeal has been dismissed by the CIT (Appeals) by way of the impugned order). 2. It has been brought to our notice that assessee Shri Dinesh Sethi has died on 14.02.2024. Death Certificate of the assessee has been annexed by the ld. counsel for the assessee

SH. DINESH SETHI,LUDHIANA vs. ITO, LUDHIANA

The appeals are dismissed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

penalty order passed u/s 271(1)(c) vide order dated 25.06.2009 against whom appeal has been dismissed by the CIT (Appeals) by way of the impugned order). 2. It has been brought to our notice that assessee Shri Dinesh Sethi has died on 14.02.2024. Death Certificate of the assessee has been annexed by the ld. counsel for the assessee

GURDISH KAUR KHULAR,JALANDHAR vs. ACIT( INTERNATIONAL TAXATION), CIRCLE, CHANDIGARH

In the result, appeal of the assessee is allowed

section 144 r.w.s 147 of the Act and made the addition of Rs. 35,01,000/-. 5. Being aggrieved the assessee carried the matter to the Ld. CIT(A) and furnished the written submission which reads as under: This is the case of assessee, individual, NRI residing in Surrey, Canada. Case was reopened u/s 147 of the Act, notice

RAM KUMAR,NEHRU GARDEN COLONY vs. ITO WARD 2 KAITHAL, AAYKAR BHAWAN, AMBALA ROAD KAITHAL

Appeal of the assessee is allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

147 of the Act. The penalty was imposed for concealment of material particulars of income of Rs. 20,70,000/-. Notices under section 274 read with section 271 of the Act, were issued on 11/12/2018 fixing the case for 14/01/2019 through post as well as through notice server. The notice sent through notice server was received back undelivered

RAM KUMAR,NEHRU GARDEN COLONY vs. ITO WARD 2, KAITHAL

Appeal of the assessee is allowed for statistical purposes

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

147 of the Act. The penalty was imposed for concealment of material particulars of income of Rs. 20,70,000/-. Notices under section 274 read with section 271 of the Act, were issued on 11/12/2018 fixing the case for 14/01/2019 through post as well as through notice server. The notice sent through notice server was received back undelivered

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

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

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

147 on that very ground would mean nothing else but the abuse of process of law. Hence, the contention of the learned DR that as the return was processed u/s. 143(1) and it was a mere intimation hence, the AO had reason to believe that income had escaped assessment and it was open to the AO to reassess

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

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

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

147 on that very ground would mean nothing else but the abuse of process of law. Hence, the contention of the learned DR that as the return was processed u/s. 143(1) and it was a mere intimation hence, the AO had reason to believe that income had escaped assessment and it was open to the AO to reassess

DINESH VERMA,MANALI, HIMACHAL PRADESH vs. ITO, ITO WARD KULLU

In the result, appeal filed by the Assessee is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

147 r.w.s. 144B on 13.03.2023 for A.Y. 2018-19 is erroneous and prejudicial to the interest of revenue. Accordingly, the same is set-aside to the file of the A.O. for the purpose of initiating penalty proceedings u/s 270A of the Act after following due procedure laid down and to take consequential action. 5. Aggrieved, the assessee has preferred

AJMAIR SINGH BHULLAR,AMRITSAR vs. DCIT, CIRCLE-1, INTERNATIONAL TAXATION, CHANDIGARH

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: JUSTICE (RETD) C.V. BHADANG (President), SHRI VIKRAM SINGH YADAV (Accountant Member)

147 were initiated in this case by issuance of notice u/s 148 dated 31.03.2021. In response, the assessee filed his return of income declaring total income of Rs.2,76,272/- on 29.04.2021. Thereafter, notice u/s 142(1) alongwith questionnaire dated 29.08.2021 and 07.09.2021 were issued to the assessee. Subsequently, a Show Cause Notice dated 03.03.2022 was also issued