TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the section 271AAB of the Act in the notice, it does not talk anything about the provisions of section 271AAB. Therefore, certainly such notice has a fatal error and technically' is not a correct notice in the eyes

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the section 271AAB of the Act in the notice, it does not talk anything about the provisions of section 271AAB. Therefore, certainly such notice has a fatal error and technically' is not a correct notice in the eyes

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the section 271AAB of the Act in the notice, it does not talk anything about the provisions of section 271AAB. Therefore, certainly such notice has a fatal error and technically' is not a correct notice in the eyes

PRAFULLA KUMAR ROUTRAY,BHUBANESWAR vs. ACIT, INTERNATIONAL TAXATION, BHUBANESWAR, BHUBANESWAR

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

25-July-2025 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-22, Kolkata [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2017-18 dated 08.01.2025, I.T.A. No.: 175/CTK/2025 Assessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

penalties were levied by the ACIT,\nRourkela Circle u/s 271(1)(c) of the Act vide even dated 30.09.2016\nfor A.Ys. 2009-10 & 2010-11.\n2. At the outset, we observe from the appeal folder that there is a delay\nof 4 days in filing the appeal by the department and in support of this\na condonation petition was filed

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

penalties were levied by the ACIT,\nRourkela Circle u/s 271(1)(c) of the Act vide even dated 30.09.2016\nfor A.Ys. 2009-10 & 2010-11.\n2. At the outset, we observe from the appeal folder that there is a delay\nof 4 days in filing the appeal by the department and in support of this\na condonation petition was filed

DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

penalties were levied by the ACIT,\nRourkela Circle u/s 271(1)(c) of the Act vide even dated 30.09.2016\nfor A.Ys. 2009-10 & 2010-11.\n2. At the outset, we observe from the appeal folder that there is a delay\nof 4 days in filing the appeal by the department and in support of this\na condonation petition was filed

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

penalties were levied by the ACIT,\nRourkela Circle u/s 271(1)(c) of the Act vide even dated 30.09.2016\nfor A.Ys. 2009-10 & 2010-11.\n2. At the outset, we observe from the appeal folder that there is a delay\nof 4 days in filing the appeal by the department and in support of this\na condonation petition was filed

M/S. ALTRADE MINERALS PVT. LIMITED,ROURKELA vs. ACIT,CENTRAL CIRCLE, SAMBALPUR, SAMBALPUR

In the result, appeal of the assessee is partly allowed

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2011-12 M/S. Altrade Minerals Pvt /S. Altrade Minerals Pvt Vs. Asst. Asst. Commissioner Commissioner Of Of Ltd., C/O. Kadmawala & Co., C/O. Kadmawala & Co., Income Tax, Central Circle, Income Tax, Central Circle, C.A., C.A., Budhram Budhram Oram Oram Sambalpur Market, Market, Kachery Kachery Road, Road, Rourkela. Pan/Gir No. No.Aafca 7136 F (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri M.R.Sahu, Ca Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 16/12/20 2024 Date Of Pronouncement : 16/12/20 024

penalty proceedings under section 271(1)(c) for the assessment year 2006- 07 is also set aside and quashed. The application being G. A. No. 81 of 2010 is also allowed. 11. No order as to costs. [Copy Enclosed CLPB-2.Pg.Nos. P a g e 47 | 63 ITA No.65/CTK /2023 Assessment Year : 2011-12 (H').TIME LIMIT SPECIFIED U/S.124