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

section 271(1)(c) despite the fact that there is neither concealment nor furnishing of inaccurate particulars. 9. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming penalty and rejecting the contention of the assessee that the penalty proceedings are independent proceedings, as such merely

INDER PAL SINGH LEGAL HEIR OF DECEASED SATNAM SINGH 171789, STREET NO.8, GURU TEG BAHADUR JAGRAON,PUNJAB vs. THE INCOME TAX OFFICER WARD-1 JAGRAON , PUNJAB

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

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

43 17/2/2018 To Cash 1045 2,00,000 44 18/2/2018 To Cash '1048 2,00,000 45 19/2/2018 To Cash 1050 2,00,000 46 20/2/2018 To Cash 1054 2,00,000 47 21/2/2018 To Cash 1057 2,00,000 48 22/2/2018 To Cash 1059 2,00,000 49 23/2/2018 To Cash 1061 2,00,000 50 24/2/2018 To Cash

M/S CORE METAL KRAFTS LTD.,CHANDIGARH vs. ACIT, C-5(1), CHANDIGARH

In the result, the appeal of the assessee is allowed

Bench: Us.

6. We have heard both the parties. In the present case penalty u/s 271(1)(c) of the Act has been levied for furnishing of inaccurate particulars of income/concealment of particulars of income and the explanation to section 271(1)(c) states that where in respect of any facts material to the computation of income the assessee does not offer

M/S PAGRO FROZEN FOODS PVT. LTD.,CHANDIGARH vs. ITO, W-2(3), CHANDIGARH

The appeal of the Assessee is dismissed

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

Penalty proceedings u/s 271(1)(c) of the I.T. Act is being initiated separately for furnishing inaccurate particulars of income. 25. The Assessee feeling aggrieved and dissatisfied with the AO’s order dt. 26/12/2016 had filed first appeal before Ld. CIT(A) who vide impugned order has dismissed the same. The core finding of CIT(A) is as follows

MANPREET SINGH BHULLAR,PARWANOO vs. ITO, PARWANOO

In the result, appeal of the assessee is allowed

43 (Punjab & Haryana) : Penalty under s. 271(1)(c)—Concealment—Bona fide belief—Where the assessee does not include a particular item in the taxable turnover or claims a deduction under bona fide belief that he is not liable so as to include the same, or entitled to deduction, it would not be right to treat the return

M/S HERITAGE MARKETING,CHANDIGARH vs. ITO, W-3(2), CHANDIGARH

In the result appeal of the assessee is allowed

Bench: Smt. Diva Singh & Ms. Annapurna Guptaassessment Year: 2013-14 M/S Heritage Marketing Vs. The Ito Sco-64, F.F., Sector-20-C Ward-3(2), Dakshin Marg, Chandigarh Chandigarh

6) of the Income Tax Act,1961,(hereinafter referred to as “Act”) , confirming the levy of penalty u/s 271(1)(c) Act. 2. Penalty in the present case has been levied on the addition made to the income of the assessee on account of difference in the Tax Deducted at Source(in short “TDS”) as reflected in Form No.26AS

M/S ASHA TECHNOLOGIES,SIRMOUR vs. ADDL. CIT, SOLAN

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

M/S ASHA TECHNOLOGIES,KALA AMB vs. ITO, SIRMOUR

In the result, both the above appeals of the Assessee are partly allowed as aforesaid in respect of impugned orders dt

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

u/s 133A of the IT Act to find out the true facts of the case when there was no compliance and cooperation on the part of the assessee to prove its primary onus. And on the basis of survey only true facts of the case were ascertained which helped in ascertaining the factual reality. The assessing office collected information u/s

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

SMT. RENU GARG,LUDHIANA vs. ITO, W-7(3), LUDHIANA

In the result, appeal of the Assessee is allowed

6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax (Appeals)-3, Ludhiana is against law and facts on the file in as much as she was not justified to arbitrarily uphold the action of the Ld. Assessing Officer in levying the penalty u/s 271(1)(c) at Rs. 11,43,300/-.” 3. From the aforesaid

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

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

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

Penalty proceedings are initiated u/s 271AAC of the Income Tax Act, 1961. The AR has also submitted that the addition in the partner's capita! account of Rs. 50 lacs should be considered as explained under the unaccounted sales transactions of Rs. 42.80 lacs in the impounded documents and other discrepancies of Rs. 7.2 lacs found during the course

SH. PRABHJIT SINGH SIDHU,MOHALI vs. DCIT, CIRCLE (INTL. TAXATION), CHANDIGARH

In the result, the appeal of the assessee is, therefore,

Bench: Shri Sanjay Garg & Ms. Annapurna Guptashri Prabhjit Singh Sidhu, Vs. The D.C.I.T., F-502, Rishi Apartment, Circle-Chandigarh Sector 70, Mohali. (International Taxation), Chandigarh. Pan: Bipps2213D (Appellant) (Respondent)

43, New Delhi (hereinafter referred to as CIT(Appeals)) dated 11.9.2017, upholding penalty levied u/s 271(1)(c) of the Income Tax Act,1961, (hereinafter referred to as “Act”) relating to assessment year 2009-10. 2. The assessee has raised the following grounds of appeal: “1. That the Ld. Commissioner of Income Tax(Appeals) has erred in law in holding

DCIT, C-5, LUDHIANA vs. M/S HERO CYCLES LTD., LUDHIANA

In the result, appeal of the Department is dismissed and the Cross

Penalty proceeding u/s 271(l)(c) is initiated separately for furnishing inaccurate particulars of income as discussed above. D) Disallowance of Interest u/s 36(l)(iii) on Share Application Money:- On the details has submitted by the assessee regarding investments it is seen that the assessee has invested certain sum of its money as mentioned below under the head share

VIMAL ALLOYS PVT LTD,MANDI GOBINDGARH vs. DC/ACIT, CIRCLE,GOBINDGARH, GOBINDGARH

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 684/Chd/2025 "नधा"रण वष" / Assessment Year: 2014-15 Vimal Alloys Pvt. Ltd., The Dc/Acit, V-Saunti, Amloh Road, Vs Circle, Mandi Gobindgarh. Mandi Gobindgarh. "थायी लेखा सं./Pan No: Aaacv7801M अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Vipen Sethi, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 09.10.2025 Date Of Pronouncement : 12.11.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

271(1)(c) of the Act vide his order dated 13.03.2020.He imposed a penalty @ 200% at Rs.32,49,546/-. 4. Dissatisfied with this penalty, assessee filed an appeal before the ld.CIT (Appeals) who has reduced the penalty to Rs.16,24,773/- by way of the impugned order. 5. It emerges out from the assessment record that assessment order was challenged

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

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

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

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