DCIT, CHANDIGARH vs. SH. KULWANT SINGH, MOHALI

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

u/s 271(l)© fail, there being no tax sought to be evaded, penalty there under cannot he levied either, as the said provision is rendered unworkable. The computation of penalty with respect to the tax at Rs. 51,54,120/- is therefore contrary to the provisions of Income Tax Act. Keeping in view the aforesaid facts, the penalty imposed

DCIT, CHANDIGARH vs. SMT. MANJIT KAUR, CHANDIGARH

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

u/s 271(l)© fail, there being no tax sought to be evaded, penalty there under cannot he levied either, as the said provision is rendered unworkable. The computation of penalty with respect to the tax at Rs. 51,54,120/- is therefore contrary to the provisions of Income Tax Act. Keeping in view the aforesaid facts, the penalty imposed

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

u/s 271(l)© fail, there being no tax sought to be evaded, penalty there under cannot he levied either, as the said provision is rendered unworkable. The computation of penalty with respect to the tax at Rs. 51,54,120/- is therefore contrary to the provisions of Income Tax Act. Keeping in view the aforesaid facts, the penalty imposed

DCIT, CHANDIGARH vs. SMT. JASWANT KAUR, MOHALI

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

u/s 271(l)© fail, there being no tax sought to be evaded, penalty there under cannot he levied either, as the said provision is rendered unworkable. The computation of penalty with respect to the tax at Rs. 51,54,120/- is therefore contrary to the provisions of Income Tax Act. Keeping in view the aforesaid facts, the penalty imposed

DCIT, CHANDIGARH vs. SH. PARAMJIT SINGH, MOHALI

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

u/s 271(l)© fail, there being no tax sought to be evaded, penalty there under cannot he levied either, as the said provision is rendered unworkable. The computation of penalty with respect to the tax at Rs. 51,54,120/- is therefore contrary to the provisions of Income Tax Act. Keeping in view the aforesaid facts, the penalty imposed

SH. JAGMOHAN SINGH,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

penalty u/s 271(1)(C) whereby the assessee has claimed deduction u/s 54 which has been denied by the AO during the course of assessment proceedings. More specifically, the charge on the assessee is that he has furnished inaccurate particulars of income by claiming deduction under Section

M/S MAHARAJA LIGHT & TENT SERVICES,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, all the above appeals of different assessees are partly allowed for statistical purposes

271(1)(c), Section 271AAA & Section 271AAB, the Legislature has restricted the scope of penal provision only to “undisclosed income” and not assessed total income. Moreover the term/expression “undisclosed income” has been defined by the Legislature in all such penal provisions in a specific and restricted manner and not in an inclusive manner. For that reason the definition of undisclosed

SMT. SHWETA JAIN,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, all the above appeals of different assessees are partly allowed for statistical purposes

271(1)(c), Section 271AAA & Section 271AAB, the Legislature has restricted the scope of penal provision only to “undisclosed income” and not assessed total income. Moreover the term/expression “undisclosed income” has been defined by the Legislature in all such penal provisions in a specific and restricted manner and not in an inclusive manner. For that reason the definition of undisclosed

SMT. VANI JAIN,LUDHIANA vs. DCIT, CC-1, LUDHIANA

In the result, all the above appeals of different assessees are partly allowed for statistical purposes

271(1)(c), Section 271AAA & Section 271AAB, the Legislature has restricted the scope of penal provision only to “undisclosed income” and not assessed total income. Moreover the term/expression “undisclosed income” has been defined by the Legislature in all such penal provisions in a specific and restricted manner and not in an inclusive manner. For that reason the definition of undisclosed

M/S SEL TEXTILES LIMITED,LUDHIANA vs. DCIT, CC-III, LUDHIANA

In the result, theappeal of the assessee stands partly allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No.695/Chd/2018 धििागरणवर्ग / Assessment Year :2014-15 बिाम M/S Sel Textiles Limited, The Dcit, 273-74,G.T. Road, Central Circle-Iii, Dhandari Kalan, Ludhiana Ludhiana स्थायीलेखासं./Pan No: Aancs0401M अपीलाथी/Appellant प्रत्यथी/Respondent धििागररतीकीओरसे/Assessee By : Shri Ashwani Kumar, Ca राजस्वकीओरसे/ Revenue By : Sh. Ram Mohan, Cit Dr सुिवाईकीतारीख/Date Of Hearing : 28.01.2019 उदघोर्णाकीतारीख/Date Of Pronouncement : 18.04.2019 आदेश/Order Per Sanjay Garg:

271(1)(c), Section 271AAA & Section 271AAB, the Legislature has restricted the scope of penal provision only to “undisclosed income” and not assessed total income. Moreover the “undisclosed income” term/expression has been defined by the Legislature in all such penal provisions in a specific and restricted manner and not in an inclusive manner. For that reason the definition of undisclosed

SHRI PARDEEP KUMAR JAIN,ZIRAKPUR vs. ITO, W-2(3), CHANDIGARH

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

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No. 190/Chd/2019 "नधा"रणवष" / Assessment Year : 2012-13 Shri Pradeep Kumar Jain, The Ito, Ward 2(3), बनाम Chandigarh Flat No.222, Orbit Apartments, 6Th Floor, Zirakpur "थायीलेखासं./Pan No: Advpj6719P अपीलाथ"/Appellant ""यथ"/Respondent

penalty proceedings u/s 271 (1)(c) of the Income Tax Act, 1961, that the assessee came to know about the passing of the appellate order. Thereafter, the assessee applied for certifiedof the order of the CIT(A) which was provided to him on 20.2.2019 and the appeal was filed immediately within the period of limitation. The above averments made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

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

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

u/s 271(1)(C), the assessee moved in appeal before the ld CIT(A) and who vide his impugned order dated 25/06/2019 has confirmed the levy of penalty and against the said order and findings of the ld CIT(A), the assessee is in appeal before us. 7. During the course of hearing, the ld AR reiterated the submissions made

SH. ROSHAN LAL JINDAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

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

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumarआयकर अपील सं./ Ita No.1555/Chd/2017 "नधा"रण वष" / Assessment Year : 2009-10

section 271AAA is not leviable. 11. In view of the above judicial precedents we find that the assessee has specified and substantiated the manner of earning the income and has not violated any of the conditions specified u/s 271AAA(2), for granting immunity from penalty. 12. We therefore hold that no penalty u/s 271AAA could be levied in the present