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20 results for “penalty u/s 271”+ Section 10(20)clear

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Key Topics

Section 44B20Section 153A20Section 14717Addition to Income16Section 915Section 153D8Section 2637Section 1485Reopening of Assessment

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

5
Section 2504
Disallowance4
Survey u/s 133A3

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 2956/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

MI OVERSEAS LTD.,NEW DELHI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3072/DEL/2012[2009-10]Status: DisposedITAT Dehradun08 Jun 2021AY 2009-10

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

20. In view of the above submission, the ground number 2 of the appeal with respect to the taxability of reimbursement expenditure of ₹ 4,020,318/– is includible in gross receipt while computing the profit u/s 44 BB of the income tax act. In the result, ground 2 of the appeal is dismissed. 21. The ground number 3 is with

DCIT, CENTRAL CIRCLE, DEHRADUN vs. SWARNGANGA CONSTRUCTION P.LTD, BHILWARA

In the result, both the appeals of the revenue are allowed for statistical purposes

ITA 186/DDN/2019[2012-13]Status: DisposedITAT Dehradun14 Dec 2021AY 2012-13

Bench: Shri R.K. Panda & Shri V.P. Rao

For Appellant: Sh. N.S. Jangpangi, CIT/DRFor Respondent: Sh. Kapil Goel, Advocate
Section 144Section 153CSection 249(3)Section 250(4)Section 271(1)(c)

penalty u/s 271(1)(c) of IT Act 1961.” 8. The Assessing Officer has computed the total income of the assessee at Rs.3,38,95,000/- which was challenged by the assessee before the CIT(A) by filing a belated appeal. Before the CIT(A), assessee has also filed additional evidence to explain the source of various transaction of investment/purchase

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 79/DDN/2024[2015-16]Status: DisposedITAT Dehradun29 Oct 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode]

Section 147Section 148Section 234ASection 250Section 271(1)(b)Section 69A

penalty order, both dated 07.09.2022 passed u/s 271(1)(b) of the Act for Assessment Years 2014-15 & 2015-16 respectively. ITA Nos.64, 78 & 79/DDN/2024 2. As these three appeals are having the issues which are inter- linked, inter-connected and this fact has been admitted by both the parties during the course of hearing before us, therefore, all three

SCHLUMBERGER ASIA SERVICES LTD.,GURGAON vs. DDIT, DEHRADUN

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6437/DEL/2014[2011-12]Status: DisposedITAT Dehradun05 May 2022AY 2011-12

Bench: Shri R.K. Panda & Shri C.N. Prasad[Assessment Year: 2011-12] Schlumberger Asia Services Deputy Director Of Income Tax Limited, (International Taxation), 14Th Floor, Tower C, Building Dehradun No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan-Aadcs1107J Assessee Revenue [Assessment Year: 2011-12] Deputy Director Of Income Tax Schlumberger Asia Services (International Taxation), Limited, Dehradun 14Th Floor, Tower C, Building No.1, Dlf City, Phase Ii, Gurgaon-122002 Pan- Aadcs1107J Revenue Assessee Assessee By Sh. Salil Kapoor, Adv. Ms. Ananya Kappor & Ms. Soumya Singh, Adv. Revenue By Sh. T.S.Mapwal, Sr.Dr

Section 143(3)Section 44BSection 44DSection 9

271(l)(c) of the Act. These grounds are dismissed on the ground that mere initiation of penalty is not an appellable matter. 12. In the result, this appeal is partly allowed.” 5. Aggrieved with such part relief, the assessee as well as the Revenue are in appeal before the Tribunal by raising the following grounds:- Revenue’s Appeal

SH.SANJAY RAWAT,,DEHRADUN vs. ACIT, CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 104/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CRICLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 95/DDN/2024[2013-14]Status: DisposedITAT Dehradun11 Feb 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

SANJAY RAWAT,DEHRADUN vs. ACIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 90/DDN/2024[2015-16]Status: DisposedITAT Dehradun11 Feb 2026AY 2015-16

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] Ita Nos.90, 95 & 104/Ddn/2024 [Assessment Years : 2015-16, 2013-14 & 2013-14] Sanjay Rawat Vs Acit 18S Ats Colony, Central Circle Sahastradhara Road, Dehradun, Dehradun, Uttarakhand-248001 Uttarakhand Pan-Ahopr5244E Appellant Respondent Assessee By Shri Ajay Wadhwa, Adv. Shri Shivam Garg, Adv. & Shri Raghav Sharma, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 11.02.2026 Order Per Manish Agarwal, Am :

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 271

271(1(c) of the Act for AY 2013-14 respectively. ITA Nos.90, 95 & 104/DDN/2024 2. At the time of hearing, it was stated that the issues involved in all the captioned appeals are common, interlinked and arising as a result of survey action thus, all these appeals have been heard together and adjudicated by this common order. First

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, the appeal of the assessee is partly allowed

ITA 7/DDN/2021[2016-17]Status: DisposedITAT Dehradun14 Dec 2021AY 2016-17

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

For Appellant: Sh. Ajay Vohra, Sr. AdvocateFor Respondent: Sh. N.S. Jangpangi, CIT/DR
Section 143(3)Section 144C(13)Section 144C(5)Section 44C

penalty proceedings under section 271(1)(c) of the Act. 16.3 The Appellant submits that each grounds of appeal are without prejudice to one another 16.4 The Appellant craves leave to add, alter, amend, substitute and / or modify in any manner whatsoever all or any of the foregoing grounds of objections at or before the hearing ofthe appeal.” 2. Ground

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

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

ITA 13/DDN/2022[2015-16]Status: DisposedITAT Dehradun27 Dec 2022AY 2015-16

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

20: General 20.1 The Appellant submits that the AO, TPO and DRP have erred in arriving various unwarranted and erroneous conclusions unsupported by any relevant material in deciding the case. 20.2 The AO erred in initiating penalty proceedings under section 271(1 )(c) of the Act. 20.3 The Appellant submits that each grounds of appeal are without prejudice

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN

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

ITA 47/DDN/2022[2018-19]Status: DisposedITAT Dehradun27 Dec 2022AY 2018-19

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. Mayak Kumar, JCIT, DR
Section 143(3)Section 144C(5)

20: General 20.1 The Appellant submits that the AO, TPO and DRP have erred in arriving various unwarranted and erroneous conclusions unsupported by any relevant material in deciding the case. 20.2 The AO erred in initiating penalty proceedings under section 271(1 )(c) of the Act. 20.3 The Appellant submits that each grounds of appeal are without prejudice

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 165/DDN/2019[2013-14]Status: DisposedITAT Dehradun27 May 2022AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

Section 132Section 153Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 153D

20. That in view of the facts and circumstances of the case CIT(A) after admitting the additional evidences u/r 46A has ignored the said evidences and have not dealt with merits of such evidences and has also failed to appreciate the contents of such evidences. 21. That the CIT(A) has erred in law and on facts in upholding

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 166/DDN/2019[2010-11]Status: DisposedITAT Dehradun27 May 2022AY 2010-11

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

Section 132Section 153Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 153D

20. That in view of the facts and circumstances of the case CIT(A) after admitting the additional evidences u/r 46A has ignored the said evidences and have not dealt with merits of such evidences and has also failed to appreciate the contents of such evidences. 21. That the CIT(A) has erred in law and on facts in upholding

SANJAY BANSAL,DEHRADUN vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 163/DDN/2019[2008-09]Status: DisposedITAT Dehradun27 May 2022AY 2008-09

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

Section 132Section 153Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 153D

20. That in view of the facts and circumstances of the case CIT(A) after admitting the additional evidences u/r 46A has ignored the said evidences and have not dealt with merits of such evidences and has also failed to appreciate the contents of such evidences. 21. That the CIT(A) has erred in law and on facts in upholding

SANJAY BANSAL,NEW DELHI vs. DCIT CENTRAL CIRCLE, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 164/DDN/2019[2009-10]Status: DisposedITAT Dehradun27 May 2022AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Challa Nagendra Prasad

Section 132Section 153Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 153D

20. That in view of the facts and circumstances of the case CIT(A) after admitting the additional evidences u/r 46A has ignored the said evidences and have not dealt with merits of such evidences and has also failed to appreciate the contents of such evidences. 21. That the CIT(A) has erred in law and on facts in upholding