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 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

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.

2. The Ld. CIT(A) erred in maintaining the penalty order passed u/s 271 E of the Income Tax Act, when the said order was time barred by limitation of time. The assessment or er is passed on 26.12.2017 and the penalty u/s 271 E should have been levied before the end of the year, 31st March 2018 or within

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.

2. The Ld. CIT(A) erred in maintaining the penalty order passed u/s 271 E of the Income Tax Act, when the said order was time barred by limitation of time. The assessment or er is passed on 26.12.2017 and the penalty u/s 271 E should have been levied before the end of the year, 31st March 2018 or within

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

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

2 Arun Majeed search seizure operations were conducted in the residential premises of the assessee u/s. 132 of the Act on 18.12.2013. Consequently the AO issued notice u/s. 153A of the Act. In response to the notice u/s. 153A, the appellant filed return of income on 30.03.2016 disclosing total income of Rs. 8,53,43,930/- by disclosing additional income

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

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

2 ITANo871/Coch/ 2022 (AY 2013-14) SA Nos. 63/Coch/2022 Mannarakkd Rural SCB vs. ITO defended by the assessee stating that the audit was carried under the Co-operative Societies Act, which would suffice. Upholding the imposition of penalty, the Hon'ble Court held that the mere fact that the audit was conducted under the Co-operative Societies Act would

KANICHUKULANGARA SERVICE CO-OPERATIVE BANK LIMITED,KANICHUKULANGARA vs. INCOME TAX OFFICER, ALAPPUZHA

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

Bench: SHRI. INTURI RAMA RAO (Accountant Member), SHRI. ANIKESH BANERJEE (Judicial Member)

14,86,418/- in financial statement. The Ld.AO rejected the expense claimed by the assessee and rejected the deduction u/s 80P of the Act. Accordingly, the profit of the assessee was determine amounting to Rs.44,94,201/-. Finally the penalty proceeding u/s 270A was initiated against the assessee. The assessee complied the notice u/s 270A of the Act in 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

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