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57 results for “penalty u/s 271”+ Section 143(2)clear

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Key Topics

Section 271(1)(c)62Section 153A42Addition to Income42Section 143(3)36Section 153D36Section 14730Penalty29Section 1027Section 44B

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

Showing 1–20 of 57 · Page 1 of 3

26
Section 27422
Disallowance9
Reopening of Assessment7

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

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

271 ITR 395 (Uttaranchal), CIT v. Madras Fertilizers Ltd. [1984] 149 ITR 703 (Mad) and CIT v. Ranoli Investment P. Ltd. [1999] 235 ITR 433 (Guj). Thus for assessment year 2006 – 07, the assessee cannot be subjected to interest u/s 234B of the income tax act. This is also for the reason that proviso inserted u/s

ASSISTANT COMMISSIONER OF INCOME TAX, DEHRADUN vs. SEABIRD EXPLORATION FZ-LLC, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 134/DDN/2024[2012-13]Status: DisposedITAT Dehradun18 Feb 2026AY 2012-13

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)Section 44B

143(3)/144C(13) of the Act. AO further initiated penalty proceedings u/s 271(1)(c) of the Act for concealment of income. Thereafter, the AO proceeded to conclude the pending penalty proceedings and in terms of order passed u/s 271(1)(c) of the Act dated 31.10.2019 imposed a penalty of INR 7,09,14,142/- being

M/S KUMAON MANDAL VIKASH NIGAM LTD.,NANITAL vs. ACIT, CIRCLE-3, NANITAL

In the result, the appeal of the assesse is allowed

ITA 44/DDN/2025[2013-14]Status: DisposedITAT Dehradun09 Jul 2025AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 271Section 271(1)(c)Section 274(1)

143(3) r.w.s 142(2A) of the Income Tax Act, 1961 M/s Kumaon Mandal Vikash Nigam vs. ACIT vide order dated 14.07.2016 by making various additions/disallowances. Thereafter, the impugned order of penalty u/s 271(1)(c) of the Act was passed on 26.03.2019 wherein penalty of Rs.3,25,735/- was levied u/s 271(1)(c) of the Act for concealment

SH.MOHIT BATOLA,DEHRADUN vs. ACIT, CC, DDN, DEHRADUN

In the result, appeal of the assessee is allowed

ITA 101/DDN/2024[2010-11]Status: DisposedITAT Dehradun30 Oct 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2010-11] Mohit Batola Vs Acit 155, Village Miyanwala Central Circle P.O.-Harrawala, Dehradun, Dehradun, Uttarakhand Uttarakhand-248001 Pan-Aftpb3533M Appellant Respondent Assessee By Shri Verendra Kalra, Ca Revenue By Shri S.K.Chaterjee, Cit Dr Date Of Hearing 05.08.2025 Date Of Pronouncement 30.10.2025 Order

Section 132Section 142(1)Section 143(2)Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 250Section 271(1)(c)Section 274(1)

143(2) was issued and subsequently questionnaire alongwith notice u/s 142(1) was issued. In response assessee filed written explanation. During the course of search, books of accounts in the Tally software were taken from the computer of the assessee as seized documents. These books of accounts were incomplete and not properly maintained and having discrepancies in the opening

HOTEL PRESIDENT,HALDWANI vs. CIT(A)-NFAC, DELHI

In the result, Appeals filed by the Assesseesare allowed

ITA 9/DDN/2025[2012-13]Status: DisposedITAT Dehradun16 Jul 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 9/Ddn/2025 (A.Y 2012-13) I.T.A. No. 10/Ddn/2025 (A.Y 2013-14) I.T.A. No. 11/Ddn/2025 (A.Y 2010-11)

Section 143(3)Section 147Section 271Section 271(1)Section 271(1)(c)Section 274

2. Brief facts of the case are that, pursuant to the assessment orders for Assessment Years 2012-13, and 2013-14 & 2010-11 passed u/s 143(3) r.w. Section147 of the Act, penalty proceedings u/s 271(1) (c) of the Act were initiated against the Assessee and orders of penalty have been passed on 17/03/2022 for all the above three

HOTEL PRESIDENT,HALDWANI vs. CIT(A)-NFAC, DELHI

In the result, Appeals filed by the Assesseesare allowed

ITA 10/DDN/2025[2013-14]Status: DisposedITAT Dehradun16 Jul 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 9/Ddn/2025 (A.Y 2012-13) I.T.A. No. 10/Ddn/2025 (A.Y 2013-14) I.T.A. No. 11/Ddn/2025 (A.Y 2010-11)

Section 143(3)Section 147Section 271Section 271(1)Section 271(1)(c)Section 274

2. Brief facts of the case are that, pursuant to the assessment orders for Assessment Years 2012-13, and 2013-14 & 2010-11 passed u/s 143(3) r.w. Section147 of the Act, penalty proceedings u/s 271(1) (c) of the Act were initiated against the Assessee and orders of penalty have been passed on 17/03/2022 for all the above three

HOTEL PRESIDENT,HALDWANI vs. CIT(A)-NFAC, DELHI

In the result, Appeals filed by the Assesseesare allowed

ITA 11/DDN/2025[2010-11]Status: DisposedITAT Dehradun16 Jul 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 9/Ddn/2025 (A.Y 2012-13) I.T.A. No. 10/Ddn/2025 (A.Y 2013-14) I.T.A. No. 11/Ddn/2025 (A.Y 2010-11)

Section 143(3)Section 147Section 271Section 271(1)Section 271(1)(c)Section 274

2. Brief facts of the case are that, pursuant to the assessment orders for Assessment Years 2012-13, and 2013-14 & 2010-11 passed u/s 143(3) r.w. Section147 of the Act, penalty proceedings u/s 271(1) (c) of the Act were initiated against the Assessee and orders of penalty have been passed on 17/03/2022 for all the above three

EKSHAD AHAMAD PATODI,U S NAGAR vs. ACIT(OSD), WARD-2(3)(5), KHATIMA

In the result, the Appeal filed by the assessee is allowed

ITA 76/DDN/2019[2012-13]Status: DisposedITAT Dehradun15 Dec 2022AY 2012-13

Bench: Dr. B. R. R. Kumar & Shri Yogesh Kumar Us

Section 143(3)Section 271Section 271(1)Section 271(1)(c)Section 274Section 40A(3)

143(3) of I.T. Act, 1961 on the total income 704660/- in the assessee status of individual issued notice of demand and challan. Issued Penalty u/s 274 read with Section 271(1)(c) of the I.T. Act, 1961. 5. Further in Page No. 2

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

143(3)/144C(3)(a) of Income Tax Act, 1961 determining the total income of the assessee at Rs.260,74,25,630/- after making the following adjustments/disallowances:- i. Bifurcated income between production sharing contractors (‘PSC’) and Non-PSC contractorsfor income from rental of equipment treating the same as Royalty under section 9(l)(vi) of the Act and taxing income

M/S. KOHLI REATORS (P) LTD.,NEW DELHI vs. DCIT, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 2197/DEL/2017[2011-12]Status: DisposedITAT Dehradun24 Nov 2021AY 2011-12

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2011-12

For Appellant: Sh. K.K. Juneja, AdvocateFor Respondent: Sh. N.S. Jangpangi, CIT/DR
Section 132Section 143Section 143(3)Section 153ASection 271(1)(c)Section 36(1)(iii)

2. At the time of hearing, learned AR of the assessee has pointed out that the quantum appeal has been decided by this Tribunal in favour of the assessee, quashing the assessment and the additions made by the Assessing Officer against which penalty was levied u/s. 271(1)(c) of the Income-tax Act has been deleted vide order dated

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 64/DDN/2024[2014-15]Status: DisposedITAT Dehradun29 Oct 2025AY 2014-15
Section 147Section 148Section 234ASection 271(1)(b)Section 69A

penalty order,\nboth dated 07.09.2022 passed u/s 271(1)(b) of the Act for\n Assessment Years 2014-15 & 2015-16 respectively.\nPage | 1\n2. As these three appeals are having the issues which are inter-\nlinked, inter-connected and this fact has been admitted by both the\nparties during the course of hearing before us, therefore, all three\nappeals

SHRI PURAN CHAN & CO.,DEHRADUN vs. DCIT, CC-DEHRADUN, DEHRADUN

In the result, Appeal of the Assessee is partly allowed

ITA 111/DDN/2025[2016-17]Status: DisposedITAT Dehradun14 Nov 2025AY 2016-17
Section 143(3)Section 271(1)(C)Section 271(1)(c)Section 274

143(3) of the Act on\n28/12/2018. Aggrieved by the assessment order, the Assessee preferred\nan Appeal before the Ld. CIT(A) and the Ld. CIT(A) vide order dated\n17/01/2024, deleted certain additions and also sustained certain\naddition. Thereafter, notice u/s 271(1)(c) of the Act were issued on\n28/12/2018 and on 02/02/2018. An order of penalty came

BEER SINGH BISHT,PAURI vs. THE INCOME TAX OFFICER, WARD-1(4)(3), KOTHDWAR

In the result, appeal of the assessee is allowed

ITA 42/DDN/2021[2014-15]Status: DisposedITAT Dehradun23 Jun 2023AY 2014-15
Section 143(3)Section 147Section 148Section 271(1)Section 271(1)(c)Section 274

2. The only issue to be decided in this appeal is as to whether the NFAC was justified in confirming the levy of penalty u/s 271(1)(c ) of the Income Tax Act, 1961 [hereinafter referred to as the ‘Act’] in the facts and circumstances of the instant case. AY: 2014-15 3. We have heard the rival submissions

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