M/S PAZHAYANGADI G GOLD,KANNUR vs. ITO WARD 1 & TPS, KANNUR

In the result, the appeal by the assessee is dismissed

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2018-19 Pazhayangadi G Gold, Ito, Ward-1& Tps, Eazhome Pazhayangadi, Kannur Kannur-670303 Vs. Pan : Aaufp9485G (Appellant) (Respondent) For Assessee : Shri Arun Raj S. Adv. For Revenue : Shri Sanjit Kumar Das, Cit-Dr (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025 O R D E R

u/s 270A was under a wrong section. The order of the AO was erroneous and prejudicial to the interest of revenue. Hence the order of the AO is set aside to the extent of non-initiation of penalty proceedings under the correct section. The AO is directed to pass fresh order accordingly.” Being aggrieved, the assessee is in appeal before

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD ,PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,M G ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

PANNIVIZHA SERVICE COOPERATIVE BANK LTD 891,MG ROAD PANNIVIZHA vs. ITO, WARD 2, KOLLAM

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Section 80P(2)(d) of the Act in the return of income for the Assessment Years 2012-2013, 2013-2014 and 2014-2015 in respect of the interest income received from Banks and Treasury: Appeal No. Interest from Bank & Treasury Penalty u/s 271

INDIRA GANDHI MEMORIAL TRUST,NELLIKUZHY P.O vs. JOINT COMMISSIONER OF INCOME TAX (EXEMPTIONS), ERNAKULAM

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

section 271E imposing penalty of Rs 34 lakhs on the appellant. b) Any other order which this Hon'ble Tribunal deem fit and proper and in the circumstances of the case.” 12. In this appeal the assessee had challenged the order of the CIT(A) in which the ld CIT had confirmed the penalty levied u/s 271

INDIRA GANDHI MEMORIAL TRUST,NELLIKUZHY, KOTHAMANGALAM vs. JOINT COMMISSIONER OF INCOME TAX(EXEMPTION), ERNAKULAM

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

section 271E imposing penalty of Rs 34 lakhs on the appellant. b) Any other order which this Hon'ble Tribunal deem fit and proper and in the circumstances of the case.” 12. In this appeal the assessee had challenged the order of the CIT(A) in which the ld CIT had confirmed the penalty levied u/s 271

SHRI.PRAKASH R. NAIR,KOLLAM vs. DCIT, KOLLAM

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

Bench: Shri Sanjay Arora & Shri Manomohan Dasprakash R. Nair Dy.Cit, Central Circle Prop. Dhanya Foods Kollam Kochuppilammoodu Vs. Kollam 691001 [Pan:Abfpn4424P] (Appellant) (Respondent)

penalty proceedings u/s. 271(1)(c) of the Act vide notice u/s. 274 of even date: 2 Prakash R. Nair v. Dy.CIT, Central Circle i. Claim for deduction u/s 80IA(Rs.68,82,867/-) was rejected. ii. Bank interest of Rs. 3,13,508/- was assessed as ‘Income from Other Sources’. iii. The claim for deduction u/s 80HHC was restricted with

SAI EXPORT ENTERPRISES,KOLLAM vs. ITO, WARD 1 & TPS, KOLLAM

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2016-17 Sai Export Enerprises .......... Appellant Mangad P.O., Kollam 691015 [Pan: Absfs2716A] Vs. The Income Tax Officer, Wd-1 & Tpo, Kollam .......... Respondent Appellant By: Shri Rajakannan, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 31.03.2024 For Assessment Year (Ay) 2016-17. 2. Brief Facts Of The Case Are That The Appellant Is A Partnership Firm. It Is Engaged In The Business Of Processing & Export Of Cashew Nuts. The Return Of Income For Ay 2016-17 Was Filed On 17.02.2017 Declaring Income Of Rs. 42,15,670/-. Against The Said Return Of Income, The Assessment Was Completed By The National

13,88,632/- being the belated remittance of employees’ contribution to PF and ESE remitted beyond the due date specified in the respective Acts, but before the due date for filing the return of income. While the matter stood thus, the AO initiated penalty proceedings u/s. 274 r.w.s. 271(1)(c) of the Act for furnishing inaccurate particulars of income

DEPUTY COMMISSIONER OF INCOME TAX, THIRUVANANTHAPURAM vs. RAJAKUMARI SHOPPING AMALL LLP, ATTINGAL

In the result, the appeal of the revenue is dismissed

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Dcit, Central Circle .......... Appellant Aayakar Bhavan, Kawdiar, Thiruvananthapuram Vs. Rajkumari Shopping Mall Llp ......... Respondent Amc 11/556, City Plaza, Nh Road Attingal 695101 [Pan: Aaqfr1222B] Assessee By: Shri V.M. Veeramani, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

section 271(1)(c) of the Act, date of order 26/09/2023. 2. The brief facts of the case are that the assessee’s case was assessed u/s 144 r.w.s. 263 of the Act, passed on 30/03/2023. The addition was confirmed u/s 68 of the Act related to unexplained credit amount to Rs.9,56,04,655/-. The Ld.AO initiated the penalty

ATTU PURATTU ISMAIL,THALASSERY vs. INCOME TAX OFFICER, WARD-2, , KANNUR

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

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2013-14 Attupurattu Ismail .......... Appellant Attupuratt House, Thalassesry, Kannur 670676 [Pan: Abfbi7471M] Vs. The Income Tax Officer, Ward-2, Kannur ......... Respondent Assessee By: Shri Ananthakrishnan R. Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 07.11.2025 Date Of Pronouncement: 19.11.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 01.09.2025 For Assessment Year (Ay) 2013-14. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. The Return Of Income For Ay 2013-14 Was Filed On 22.03.2014 Disclosing Total Income Of Rs. 2,63,300/-. The Search & Seizure Operations U/S. 132 Of The Income Tax Act, 1961 (The Act) Was Conducted In The Business Premises Of Parco Group Of Concerns

13,035/- vide order dated 27.03.2025 passed u/s. 271(1)(c) of the Act. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the penalty. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The learned counsel for the assessee contended before us that

M/S. THE THIRUNELLY SERVICE CO-OPERATIVE BANK,WAYANAD vs. JCIT, RANGE-2, KOZHIKODE

In the result, appeal filed by the assessee stands dismissed

u/s. 271D, no penalty can be levied placing reliance on the decision of Hon'ble Supreme Court in the case of case of CIT Vs. Jai Laxmi Rice Mills (2015) 379 ITR 521 (SC). 9. On the other hand, ld. CIT-DR placing reliance on the decision of this Tribunal in the case of The Nadapuram Service Co-op. Bank

HIGH RANGE FOODS PRIVATE LIMITED,ERNAKULAM vs. DCIT CORPORATE CIR 1(1), KOCHI

In the result, the appeal by the assessee is allowed

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2014-15 High Range Foods Private Dcit, Corporate Circle-1(1) Limited, Kochi 28/3030, Vs. Cheruparambath Road, Kadavanthra, Ernakulam-682020 Pan : Aaach6076L (Appellant) (Respondent) For Assessee : Shri P.M. Veeramani, Ca For Revenue : Smt. Leena Lal (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025

271(1)(c) of the Act on this issue is not justifiable, and accordingly the same is deleted. 8. The last issue that arises for our consideration pertains to the levy of penalty u/s.271(1)(c)of the Act in respect of the addition 5 made on account of interest received by the assessee on refund u/s. 244A

KADUNGAMPARAMBIL MANUAL GEORGE JOSEPH,ERNAKULAM vs. ITO , NON CORPORATE WARD 2(4) & TPS, KOCHI

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

13 13/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 143(3) r.w.s. 23/1046317013(1) 147 14 14/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271B 23/1046317423(1) 15 15/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271(1)(c) 23/1046317203(1) 16 16/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 271AAC1 23/1046338750(1) 17 17/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 270 23/1046339605(1) 18 2017-18 18/Coch/2023 ITBA/NFAC/S/250/2022- 143(3) 23/1046338190(1) Heard both parties at length. Case

KADUNGAMPARAMBIL MANUAL GEORGE JOSEPH,ERNAKULAM vs. ITO , NON CORPORATE WARD 2(4) & TPS, KOCHI

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

13 13/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 143(3) r.w.s. 23/1046317013(1) 147 14 14/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271B 23/1046317423(1) 15 15/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271(1)(c) 23/1046317203(1) 16 16/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 271AAC1 23/1046338750(1) 17 17/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 270 23/1046339605(1) 18 2017-18 18/Coch/2023 ITBA/NFAC/S/250/2022- 143(3) 23/1046338190(1) Heard both parties at length. Case

KADUNGAMPARAMBIL MANUAL GEORGE JOSEPH,ERNAKULAM vs. ITO , NON CORPORATE WARD 2(4) & TPS, KOCHI

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

13 13/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 143(3) r.w.s. 23/1046317013(1) 147 14 14/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271B 23/1046317423(1) 15 15/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271(1)(c) 23/1046317203(1) 16 16/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 271AAC1 23/1046338750(1) 17 17/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 270 23/1046339605(1) 18 2017-18 18/Coch/2023 ITBA/NFAC/S/250/2022- 143(3) 23/1046338190(1) Heard both parties at length. Case

KADUNGAMPARAMBIL MANUAL GEORGE JOSEPH,ERNAKULAM vs. ITO , NON CORPORATE WARD 2(4) & TPS, KOCHI

Appeals are allowed for statistical purposes in above terms

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

13 13/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 143(3) r.w.s. 23/1046317013(1) 147 14 14/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271B 23/1046317423(1) 15 15/Coch/2023 2015-16 ITBA/NFAC/S/250/2022- 271(1)(c) 23/1046317203(1) 16 16/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 271AAC1 23/1046338750(1) 17 17/Coch/2023 2017-18 ITBA/NFAC/S/250/2022- 270 23/1046339605(1) 18 2017-18 18/Coch/2023 ITBA/NFAC/S/250/2022- 143(3) 23/1046338190(1) Heard both parties at length. Case