DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

B) to section 271(1)(c) of the Act was not fulfilled and, therefore, Assessing officer has rightly imposed / levied penalty. That as per Explanation 1 to section 271(1)(c) of the Act, it was not necessary for the Assessing officer to add or to disallow something to attract the penalty provisions. Further, as per the Explanation

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

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

B) to section 271(1)(c) of the Act was not fulfilled and, therefore, Assessing officer has rightly imposed / levied penalty. That as per Explanation 1 to section 271(1)(c) of the Act, it was not necessary for the Assessing officer to add or to disallow something to attract the penalty provisions. Further, as per the Explanation

DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

B) to section 271(1)(c) of the Act was not fulfilled and, therefore, Assessing officer has rightly imposed / levied penalty. That as per Explanation 1 to section 271(1)(c) of the Act, it was not necessary for the Assessing officer to add or to disallow something to attract the penalty provisions. Further, as per the Explanation

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

B) to section 271(1)(c) of the Act was not fulfilled and, therefore, Assessing officer has rightly imposed / levied penalty. That as per Explanation 1 to section 271(1)(c) of the Act, it was not necessary for the Assessing officer to add or to disallow something to attract the penalty provisions. Further, as per the Explanation

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

B) to section 271(1)(c) of the Act was not fulfilled and, therefore, Assessing officer has rightly imposed / levied penalty. That as per Explanation 1 to section 271(1)(c) of the Act, it was not necessary for the Assessing officer to add or to disallow something to attract the penalty provisions. Further, as per the Explanation

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)

153A ,had not been declared in the original return of income filed and the additional income declared after search represented concealed income and hence tantamounted to incriminating material for attracting Explanation 5A to section 271(1)(c) of the Act. 4. Aggrieved by the same the assessee has come up in appeal before us raising the following effective ground: “1

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

153A is accepted by the Assessing Officer, there will be no concealment of income and consequently penalty u/s 271(1)(c) of the Act cannot be imposed. 17. The Ld. counsel for assessee also relied upon the decision of various Tribunals in this context which were referred before the Ld.CIT(Appeals) also. 18. The Ld. DR, on the other hand

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

153A is accepted by the Assessing Officer, there will be no concealment of income and consequently penalty u/s 271(1)(c) of the Act cannot be imposed. 17. The Ld. counsel for assessee also relied upon the decision of various Tribunals in this context which were referred before the Ld.CIT(Appeals) also. 18. The Ld. DR, on the other hand

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

u/s 153A. The AO is directed to correct the quantum of penalty in accordance with Explanation 4.” 9. We have heard the rival contentions and purused the material available on record. In the quantum proceedings, we have held that the amount received by the assessee is in the nature of interest taxable @ 15% under Article 12 of India-UK DTAA

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

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

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