DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

22. From an analysis of Sections 271D and 271E of the Act, it is seen that both the provisions are pari materia to each other. While Section 271D of the Act would be attracted on a person accepting loan or deposit or specified sum in contravention of Section 269SS of the Act, penalty under Section 271 E

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

22. From an analysis of Sections 271D and 271E of the Act, it is seen that both the provisions are pari materia to each other. While Section 271D of the Act would be attracted on a person accepting loan or deposit or specified sum in contravention of Section 269SS of the Act, penalty under Section 271 E

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

22. From an analysis of Sections 271D and 271E of the Act, it is seen that both the provisions are pari materia to each other. While Section 271D of the Act would be attracted on a person accepting loan or deposit or specified sum in contravention of Section 269SS of the Act, penalty under Section 271 E

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, appeal filed by the Revenue is dismissed and the\nCross-Objection filed by the assessee is allowed

E R Kumar, Manager.\n5. The grounds raised by the Id. AO before the Hon'ble ITAT travelled much\nbeyond the scope of satisfaction recorded for initiation of penalty, the notice\nproposing levy of penalty, order levying penalty and order passed by Id. CIT(A)\nand hence are invalid and deserve to be dismissed.\n6. As the Appellant was never

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

2. Issue for Consideration Whether the penalty notice under Section 271AAB is invalid due to the AO's reference to "Section 271AAB(1)" instead of "Section 271AAB(1A)", despite the levy of a 60% penalty. 3. Submission It is respectfully submitted that the penalty notice is valid and the assessee's challenge lacks merit for the following reasons: a. Penalty

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

2. Issue for Consideration Whether the penalty notice under Section 271AAB is invalid due to the AO's reference to "Section 271AAB(1)" instead of "Section 271AAB(1A)", despite the levy of a 60% penalty. 3. Submission It is respectfully submitted that the penalty notice is valid and the assessee's challenge lacks merit for the following reasons: a. Penalty

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n87.\nThe AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\nwhich formed part

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

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n87.\nThe AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\nwhich formed part

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

E R PER MANJUNATHA. G, AM: These two appeals filed by the assessee are directed against separate, but identical orders of the Commissioner of Income Tax (Appeals)-20, Chennai, dated 17.08.2023 and pertains to assessment years 2015-16 & 2016-17. Since, facts are identical and issues are common, for the sake of convenience, these appeals were heard together

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

E R PER MANJUNATHA. G, AM: These two appeals filed by the assessee are directed against separate, but identical orders of the Commissioner of Income Tax (Appeals)-20, Chennai, dated 17.08.2023 and pertains to assessment years 2015-16 & 2016-17. Since, facts are identical and issues are common, for the sake of convenience, these appeals were heard together

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n87.\nThe AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\nwhich formed part

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n86.\n87. The AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\nwhich formed part

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n87.\nThe AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\nwhich formed part

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

penalty proceedings\nu/s.271AAB(1A) of the Act by issuing show cause notice u/s.274\nr.w.s 271AAB of the Act on 27.03.2022.\n87.\nThe AO show caused the assessee requiring to explain as to\nwhy penalty u/s.271AAB(1A) of the Act should not be levied in\nrespect of the undisclosed income amounting to Rs.4,42,15,889/-\n, which formed part

D.SENTHIL KUMAR,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of penalty u/s 271(1)(c) for Rs.10,36,114/- for Assessment Year (AY) 2009-10, the assessee is in further appeal before us. The impugned order has been passed by learned Commissioner of Income Tax (Appeals)-2, Coimbatore [CIT(A)] on 31-03-2017 in the matter

MERCY EDUCATION TRUST,CHENNAI vs. ITO, NCW-19(6), CHENNAI

In the result, the appeal filed by the assessee is partly-allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2231/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mercy Education Trust, The Income Tax Officer, No.66, Sree Gokulam Towers, Vs. Non-Corporate Ward 19(6), Arcot Road, Chennai. Kodambakkam, Chennai – 600 024. Pan: Aactm 6190M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 29.01.2026

271(1)(c) of the Act. In case the reassessment proceedings have been completed without proper jurisdiction entrusted upon the Assessing Officer, then the consequent penalty proceedings are also affected as basic issue of conferment of jurisdiction upon the Assessing Officer is under challenge. Accordingly, we hold so.” 21. In the context of appeal against penalty order passed u/s.271D

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

E R PER V. DURGA RAO, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals) 14, Chennai dated 30.03.2015 passed under section 271(1)(c) of the Income Tax Act, 1961 [“Act” in short]. The appeal filed by the assessee is delayed by one day in filing

M/S ENRICE ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha. G & Shri Manomohan Das

E R PER MANJUNATHA. G, AM: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals)-20, Chennai, dated 17.08.2023 and pertains to assessment year 2019-20. 2. The assessee has raised the following grounds of appeal: 1. The order of the learned Commissioner Of Income (Appeals)-20, is wrong, illegal

MANGAL & MANGAL,TRICHY vs. ACIT, TRICHY

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 2207/Chny/2019 िनधा"रण वष" / Assessment Year: 2013-14

E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: This appeal filed by the assessee is directed against the order passed by the learned Commissioner of Income Tax (Appeals)-19, Chennai, dated 11.07.2019 and pertains to assessment year 2013-14. :-2-: ITA. No: 2207/Chny/2019 2. The assessee has filed the following grounds of appeal: “1. The order of the Commissioner of Income