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

iii) The Learned AO has levied penalty under Section 271AAB(1A) in his penalty order without issuing any notice for levying such penalty. 3.2 Further, even if your Honour confirm the penalty, it is hereby reiterated that there is no 'undisclosed' income since the assessee has provided bona-fide explanation and also offered the same vide the ROI filed u/s

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].

section 271(1)(c) of the Act dated 28.03.2012. The relevant portion of the order is extracted as under: 5. The Decision: 5.1 The learned AR argued that i. The issue involved is a legal issue. ii. only a different view was taken by the assessee and the department and iii. relied on the decision of Reliance Petro Products

ST. JOSHEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

iii) on or before the specified date-\n(A) pays the tax, together with interest, if any, in respect of the undisclosed\nincome; and\n(B) furnishes the return of income for the specified previous year declaring\nsuch undisclosed income therein;\n(b) a sum computed at the rate of sixty per cent of the undisclosed income of\nthe specified

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

iii) on or before the specified date-\n(A) pays the tax, together with interest, if any, in respect of the undisclosed\nincome; and\n(B) furnishes the return of income for the specified previous year declaring\nsuch undisclosed income therein;\n(b) a sum computed at the rate of sixty per cent of the undisclosed income of\nthe specified

PVP VENTURES LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(2), CHENNAI

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

iii) Reduction in Capital WIP for Rs.228.18 Lacs; (iv) Short-Term Capital Gains on land for Rs.3107.20 Lacs. 3.2 Subsequent to framing of assessment, penalty proceedings were initiated against the issue and initial show cause notice u/s 274 r.w.s. 271(1)(c) was issued on 31.12.2010 which read as under: - Whereas in the course of proceedings before

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

36,64,425 7.7 According to AR, if these are considered, the total cost of construction accounted, works out to Rs.65.21 Lakhs (28.57 + 36.64), as against Rs.74.36 Lakhs determined by the CIT(A) in the original assessment proceedings and the variation being negligible, should be ignored. Property No.II: D.V.O. had valued the property at Rs.117.45 Lakhs, which was reduced

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

36,64,425 7.7 According to AR, if these are considered, the total cost of construction accounted, works out to Rs.65.21 Lakhs (28.57 + 36.64), as against Rs.74.36 Lakhs determined by the CIT(A) in the original assessment proceedings and the variation being negligible, should be ignored. Property No.II: D.V.O. had valued the property at Rs.117.45 Lakhs, which was reduced

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

36,64,425 7.7 According to AR, if these are considered, the total cost of construction accounted, works out to Rs.65.21 Lakhs (28.57 + 36.64), as against Rs.74.36 Lakhs determined by the CIT(A) in the original assessment proceedings and the variation being negligible, should be ignored. Property No.II: D.V.O. had valued the property at Rs.117.45 Lakhs, which was reduced

M/S. J FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

36,64,425 7.7 According to AR, if these are considered, the total cost of construction accounted, works out to Rs.65.21 Lakhs (28.57 + 36.64), as against Rs.74.36 Lakhs determined by the CIT(A) in the original assessment proceedings and the variation being negligible, should be ignored. Property No.II: D.V.O. had valued the property at Rs.117.45 Lakhs, which was reduced

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

u/s 271AAB of the Act is not mandatory but discretionary. The provisions of section 271AAB of the Act is pari materia with that of section 158BFA of the Act relating to block assessment and accordingly argued that the levy of penalty under section 271AAB is not mandatory but discretionary. When there is reasonable cause, the penalty is not exigible

ACIT CIRC LE 1, TRICHY vs. M/S DALMIA CEMENTS (BHARAT) LTD, TIRUCHIRAPALLI

In the result, appeals filed by the Revenue and cross

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.596 & 1295/Chny/2018 & C.O.Nos.55 & 57/Chny/2019 [In Ita Nos.596 & 1295/Chny/2018] ("नधा"रणवष" / Assessment Year: 2011-12 & 2012-13)

Section 271(1)(c) of the Income tax Act. 3) Further most of the rulings referred by the assessee based on the judgement of the Hon’ble Supreme Court in the case of CIT Vs. Reliance Petro Products(322 ITR 158). The facts of the case are different from this case. In the referred case the assessee claimed deduction u/s.36

ACIT CIRC LE 1, TRICHY vs. M/S DALMIA CEMENTS (BHARAT) LTD, TIRUCHIRAPALLI

In the result, appeals filed by the Revenue and cross

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.596 & 1295/Chny/2018 & C.O.Nos.55 & 57/Chny/2019 [In Ita Nos.596 & 1295/Chny/2018] ("नधा"रणवष" / Assessment Year: 2011-12 & 2012-13)

Section 271(1)(c) of the Income tax Act. 3) Further most of the rulings referred by the assessee based on the judgement of the Hon’ble Supreme Court in the case of CIT Vs. Reliance Petro Products(322 ITR 158). The facts of the case are different from this case. In the referred case the assessee claimed deduction u/s.36

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

271 (1) ( c ) on interest income and disallowance u/s 14A . 1.2 The Ld CIT(A) has erred in not providing an iota of reasoning as to how the levy is not attracted in respect of interest income and U/s 14A vide a speaking order. G1.3 For these and other grounds that may be adduced at the time of hearing

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

271 (1) ( c ) on interest income and disallowance u/s 14A . 1.2 The Ld CIT(A) has erred in not providing an iota of reasoning as to how the levy is not attracted in respect of interest income and U/s 14A vide a speaking order. G1.3 For these and other grounds that may be adduced at the time of hearing

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

271 (1) ( c ) on interest income and disallowance u/s 14A . 1.2 The Ld CIT(A) has erred in not providing an iota of reasoning as to how the levy is not attracted in respect of interest income and U/s 14A vide a speaking order. G1.3 For these and other grounds that may be adduced at the time of hearing

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

271 (1) ( c ) on interest income and disallowance u/s 14A . 1.2 The Ld CIT(A) has erred in not providing an iota of reasoning as to how the levy is not attracted in respect of interest income and U/s 14A vide a speaking order. G1.3 For these and other grounds that may be adduced at the time of hearing

ARUSUVAI FOOD PROCESSORS PVT. LTD.,SALEM vs. DCIT, CIRCLE-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

36 parties during FY 2016–17. Notices under Section 133(6) were issued to these parties. 32 parties responded with confirmations and ledgers. In 4 cases, either balance was NIL or confirmations were not received. However, in respect of 12 parties, trade advances aggregating to ₹1,70,16,220/- remained unsettled for more than 5 years. Based on the prolonged

M/S.REDINGTON DISTRIBUTIONS PTE LTD.,SINGAPORE vs. ACIT, INTLTAXATION CIRCLE-2(1), CHENNAI

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

penalty levied u/s 271(1)(c) of the Income ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2016-17) M/s. Redington Distribution Pte Ltd. :: 2 :: Tax Act, 1961 (hereinafter referred to as ‘the Act‘) on the common addition(s) made on account of the profits of the assessee attributed to be taxed in India. With the consent of both

M/S.REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. ACIT,INTL TAXATION CIRCLE-2(1), CHENNAI

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

penalty levied u/s 271(1)(c) of the Income ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2016-17) M/s. Redington Distribution Pte Ltd. :: 2 :: Tax Act, 1961 (hereinafter referred to as ‘the Act‘) on the common addition(s) made on account of the profits of the assessee attributed to be taxed in India. With the consent of both