DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

u/s 153A of the Act. That Explanation 1 to Section 271 was not applicable in the facts of the case. Further, that even explanation given by the assessee that the aforesaid additional income was earned by speculation in the sale / purchase of agricultural land had been duly mentioned in Rule 9 Report submitted before the Income Tax Settlement Commission

SH. CHETAN JAIN,LUDHIANA vs. DCIT, LUDHIANA

In the result, the appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptash.Chetan Jain, Vs. The D.C.I.T., B-121, Pushap Vihar, Central Circle-Iii, Canal Road, Ludhiana. Ludhiana. Pan: Aaypj0618H (Appellant) (Respondent)

penalty was leviable as per Explanation-5A to section 271(1)(c) of the Act. 2) When return of income filed u/s 153A

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

penalty was leviable as per Explanation-5A to section 271(1)(c) of the Act. 2) When return of income filed u/s 153A

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

penalty was leviable as per Explanation-5A to section 271(1)(c) of the Act. 2) When return of income filed u/s 153A

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

u/s 153(1) i.e. twenty one months from the end of the A Y 2010-11. Explanation 3 to section 271(1) provides as under "Explanation 3.—Where any person fails, without reasonable cause, to furnish within the period specified in sub-section (1) o f section 153 a return of his income which he is required to furnish under

PALACE INFRATECH PVT LTD,LUDHIANA vs. THE DY.COMMISSIONER OF INCOME TAX, LUDHIANA

In the result appeal of the assessee is partly allowed

Bench: Or During The Course Of Hearing.

271 shall be imposed upon the assessee in respect o f the undisclosed income referred to in sub- section (1). (3) The provisions o f sections 274 and 275 shall, as far as may be, apply in relation to the penalty referred to in this section. Explanation- For the purposes o f this section,- (a) "specified date" means

SH. ANIL TALWAR,CHANDIGARH vs. DCIT, CC-II, CHANDIGARH

In the result, the appeals of the assessee are allowed

Bench: Ms. Diva Singh & Dr. B.R.R.Kumar

153A of the Act, as such no penalty is leviable. 8. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming penalty under section 271(1)(c) despite the fact that there is neither concealment nor furnishing of inaccurate particulars. 9. On the facts and circumstances

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, , LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

271(l)(c) of the Act, the failure to obtain prior permission from the IAC for imposing penalty was only a procedural error and not fatal to the order of penalty. (vi) Since the entire documents were already available to the Additional CIT in the file sent for approval, there was no need for exchange of the said documents prior

AMAN FEED INDUSTRIES,KHANNA vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-1, LUDHIANA, LUDHIANA

In the result, appeals of the assessee for A

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 1252, 1253,1254,1255/Chd/2024 "नधा"रण वष" / A.Y.: 2015-16, 2017-18, 2018-19,2019-20 M/S Aman Feed Industries, The Dcit, E-2, Focal Point, Vs Central Circle-1, Khanna. Ludhiana. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent आयकर अपील सं./ Ita Nos. 116,181,457/Chd/2025 "नधा"रण वष" / A.Y.: 2017-18, 2018-19, 2019-20 The Dcit, Vs M/S Aman Feed Industries, Central Circle-1, E-2, Focal Point, Ludhiana. Khanna. "थायी लेखा सं./Pan No: Aacfa3624L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar, Shri Kulbhushan Goyal & Ms, Deepali Aggarwal, Cas Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 28.07.2025 Date Of Pronouncement : 16.10.2025

271(l)(c) of the Act, the failure to obtain prior permission from the IAC for imposing penalty was only a procedural error and not fatal to the order of penalty. (vi) Since the entire documents were already available to the Additional CIT in the file sent for approval, there was no need for exchange of the said documents prior