DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

145 taxmann.com 665 (Delhi) the Hon'ble\nDelhi High Court had held that Where in penalty notice,\nAssessing Officer failed to specify limb of underreporting' or\n'misreporting' of income, under which penalty proceedings had\nbeen initiated, penalty notice was erroneous and arbitrary and,\nthus, petitioner was to be granted immunity under section 270AA\n6.5.7 The undersigned upon examination

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

145 taxmann.com 665 (Delhi) the Hon'ble\nDelhi High Court had held that Where in penalty notice,\nAssessing Officer failed to specify limb of underreporting' or\n'misreporting' of income, under which penalty proceedings had\nbeen initiated, penalty notice was erroneous and arbitrary and,\nthus, petitioner was to be granted immunity under section 270AA\n6.5.7 The undersigned upon examination

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

145 taxmann.com 665 (Delhi) the Hon'ble\nDelhi High Court had held that Where in penalty notice,\nAssessing Officer failed to specify limb of underreporting' or\n'misreporting' of income, under which penalty proceedings had\nbeen initiated, penalty notice was erroneous and arbitrary and,\nthus, petitioner was to be granted immunity under section 270AA\n6.5.7 The undersigned upon examination

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

145 taxmann.com 665 (Delhi) the Hon'ble\nDelhi High Court had held that Where in penalty notice,\nAssessing Officer failed to specify limb of underreporting' or\n'misreporting' of income, under which penalty proceedings had\nbeen initiated, penalty notice was erroneous and arbitrary and,\nthus, petitioner was to be granted immunity under section 270AA\n6.5.7 The undersigned upon examination

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

145 lTD 175 and CIT Vs Goetze (India) Ltd. (Del) 97 DTR 169? 6. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing Officer restored on the above issues.” 16. The ld DR assailed

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

145 lTD 175 and CIT Vs Goetze (India) Ltd. (Del) 97 DTR 169? 6. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing Officer restored on the above issues.” 16. The ld DR assailed

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

145 lTD 175 and CIT Vs Goetze (India) Ltd. (Del) 97 DTR 169? 6. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing Officer restored on the above issues.” 16. The ld DR assailed

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

145 lTD 175 and CIT Vs Goetze (India) Ltd. (Del) 97 DTR 169? 6. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing Officer restored on the above issues.” 16. The ld DR assailed

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

penalty\nproceedings under section 274 read with section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\n\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\"\n\n4. Ground No. 1 is general in nature and hence, doesn

DCIT, TIRUNELVELI vs. M.LAZAR ADAIKALAM, TIRUNELVELI

In the result , the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

271(1) mentions "as :- 5 -: concealed.......or furnished". They are past tense words indicating that assessee has committed certain act on which penalty is leviable. Thus the act of concealment or furnishing of inaccurate particulars should be viewed by the Assessing Officer as done with respect to return of income. The omission or commission or contumacious conduct

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

penalty\nproceedings under section 274 read with section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\n\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n\n-5-\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

penalty\nproceedings under section 274 read with section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

penalty\nproceedings under section 274 read with section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

penalty\nproceedings under Section 274 read with Section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

penalty\nproceedings under section 274 read with section 271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n4. Ground No. 1 is general in nature and hence, doesn't require\nany