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

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

CHUNDAYIL KALAM GIRIJADEVI ,KERALASSERY vs. ITO WARD 1 & TPS, PALAKKAD

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

271(1)(c) of the Act, even if the claim made by him is unsustainable in law provided that he either substantiates the explanation offered by him or the explanation, even if not substantiated, is found to be bona fide. E. Where the appellant has withdrawn the claim during the course of the assessment proceedings, the penalty under section 270A

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)

2)(a)(i) of the Act as per the judgment of the Hon'ble Kerala High Court in the case of Sahyadri Co-op. Credit Society Ltd. (supra). Therefore, we hold that the Assessee should have been granted benefit of the provisions contained in Section 270A(6)(a) of the Act. Accordingly. we delete the penalty of INR.55,271 (Assessment

SRI HARIKUTTAN T,KAYAMKULAM vs. INCOME TAX OFFICER WARD 2, ALLEPPEY

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

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember Harikuttan T. The Income Tax Officer (2) 1, Edayilaveetil Tharayil Aayakar Bhavan Njakkanal P.O., Pathiyoor Vs. Alappuzha Co0Llectorate Kayalmulam 690533 Alappuzha 688011 [Pan:Alrpt7536J] (Appellant) (Respondent) Appellant By: Shri M.S. Venkitachalam, Ca Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing:08.08.2023 Date Of Pronouncement:03.11.2023 O R D E R Per Sanjay Arora, Am This Is An Appeal By Assessee Challenging The Confirmation Of Penalty Levied Under Section 270A Of The Income Tax Act, 1961 (The Act) For Assessment Year (Ay) 2017-18 Vide Order Dated 17/02/2022, By The First Appellate Authority, Being The Commissioner Of Income Tax, Nfac [Cit(A)] Vide It’S Order Dated 06.07.2022. 2.1 The Brief Background Facts Of The Case Are That The Assessee, A Retired Defence Personnel, Is A Registered Money Lender Under The Kerala Money Lenders Act (Kml Act), Lending Money On Interest Against Mortgage Of Loan. For The Relevant Year He Returned, Besides Pension, Income From This Business At Rs.2,05,691. On Verification, It Was Found By The Assessing Officer (Ao) That The Assessee Was Maintaining Six Bank Accounts, I.E., Three Each With Two Banks, Being South Indian Bank (Sib) & State Bank Of India (Sbi). Transactions With The Former Were Undisclosed. The Reason Explained Was That The Gold Pawned By His Customers With Him For Availing Loan, Was In Turn Mortgaged With This Bank To Source Funds For Further Lending. These

penalty for under-reporting income u/s. 270A(2). That is, deliberateness, which is implied inasmuch as it is the assessee, in the intimate know of his affairs, who nevertheless returns a lower income, and brought forth specifically per Explanation 1 to section 271

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book

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

271(1)(c) penalties for concealment and furnishing of inaccrate particulars of income involving varyig sums in these appeals. Learned DR seeks to submit that AY 2017-18 also involves section 270A penalty of under reporting of incomes as a consequence to misreporting. We are of the considered view that once the lower authorities have estimated the assessee’s book