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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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)

u/s 271(1)(c) (INR) (INR) 3,73,478 3,73,478 (2012-2013) 5,76,636 5,76,636 (2013-2014) 2,34,054 2,34,054 (2014-2015) 13. Since there is no change in the facts and circumstances of the case and the grounds raised by the Assessee are identical, our finding and adjudication in relation

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

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

THE SULTHAN BATHERY SERVICE CO-OP BANK LTD,WAYANAD vs. THE JCIT RANGE 2, KOZHIKODE

In the result, both the appeals in ITA Nos

Bench: Shri Chandra Poojari & Shri Soundararajan K.

section is not applicable in respect of deposits/loan accepted from Govt. and hence penalty is not leviable u/s 2711) of the Act. 6. The appellant carves leave to add, alter, modify or delete any of the ground of appeal. 7. The appellant may submit that the penalty of Rs.1,02,14,54,585/- levied u/s.271D

THE SULTHAN BATHERY SERVICE CO-OP BANK LTD,WAYANAD vs. THE JCIT RANGE 2, KOZHIKODE

In the result, both the appeals in ITA Nos

Bench: Shri Chandra Poojari & Shri Soundararajan K.

section is not applicable in respect of deposits/loan accepted from Govt. and hence penalty is not leviable u/s 2711) of the Act. 6. The appellant carves leave to add, alter, modify or delete any of the ground of appeal. 7. The appellant may submit that the penalty of Rs.1,02,14,54,585/- levied u/s.271D

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)

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 reference to section

DY.CIT, CIRCLE 1(1) & TPS, THRISSUR, THRISSUR vs. ARUN MAJEED, THRISSUR

In the result, the appeal filed by the Revenue stands allowed

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2013-14 Dy. Cit, Circle 1(1) & Tps, Thrissur .......... Appellant [Pan: Adopa9351R] Vs. Arun Majeed .......... Respondent Palak Velyannur Temple Road Veliyannur, Thrissur 680021 Appellant By: Smt. Leena Lal, Sr. D.R. Respondent By: ------- None ------- Date Of Hearing: 05.06.2025 Date Of Pronouncement: 31.07.2025

14,73,030/- by making the following additions to the returned income: - i) Capital gain Rs. 8,74,837 ii) Profit from land sale Rs. 10,66,19,832 iii) Rent Rs. 1,08,000 iv) Credits in FB Olarikkara Rs. 3,74,61,047 v) Credits in YES Bank Rs. 1,00,00,000 vi) Cash Deficit

THE KARANNUR SERVICE CO-OP BANK LTD ,KOZHIKKODE vs. THE ITO, WD-1(2),, KOZHIKKODE

In the result, the appeals by the assessee are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

271(1)(c) is reckoned from the date of the assessment order dated 5 ITANos. 248 & 249/Coch/2020 (AY: 2015-16) The Karannur Service Co-op. Bank Ltd. vs. ITO November 6, 2007, the penalty order passed by the Joint Commissioner on July 29, 2008, is beyond the time permitted in the above section. As we have already held, the initiation

M/S.KARANNUR SERVICE CO-OP BANK LTD,KOZHIKKODE vs. THE ITO, WD-1(2), KOZHIKKODE

In the result, the appeals by the assessee are allowed

Bench: Shri Sanjay Arora & Shri Manomohan Das

271(1)(c) is reckoned from the date of the assessment order dated 5 ITANos. 248 & 249/Coch/2020 (AY: 2015-16) The Karannur Service Co-op. Bank Ltd. vs. ITO November 6, 2007, the penalty order passed by the Joint Commissioner on July 29, 2008, is beyond the time permitted in the above section. As we have already held, the initiation

THE MANNARKKAD RURAL SERVICE CO OPERATIVE BANK LTD.,MANNARKKAD vs. INCOME TAX OFFICER, PALAKKAD

In the result, the assessee’s appeal and stay application are dismissed

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember

u/s. 44AB stands delinked from the obligation to file return –a default where- under is subject to penalty under a separate provision, by Finance Act, 1995, w.e.f. 01.07.1995. Even if, therefore, the assessee is not required to – as where he has no income for the relevant year, or otherwise does not his file return of income, he is yet obliged

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

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

14,00,000/-. However, he confirmed the addition of interest of Rs. 42,184/-. The AO had initiated penalty proceedings u/s. 274 r.w.s. 271(1)(c) of the Act and levied penalty of Rs. 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

SHALOM CHARITABLE MINISTRIES OF INDIA,PALAKKAD vs. ITO (EXEMPTION), THRISSUR

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

14 of the Act. Audit of a charitable trust is envisaged in section 12A(1)(b) of the Act. 4) It is submitted that micro finance activity is only a charitable activity designed in such a way that the poor sections of the society are to be benefited and to be uplifted, especially rural women who do not have substantial