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26 results for “penalty u/s 271”+ Section 20clear

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Key Topics

Section 153A20Section 44B20Section 14719Addition to Income19Section 916Section 1489Section 153D8Section 271(1)(c)7Section 263

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

Showing 1–20 of 26 · Page 1 of 2

7
Penalty6
Disallowance6
Reopening of Assessment5

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

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

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

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

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

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 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

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

SHRI PRITPAL SINGH,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, DEHRADUN

In the result, the appeal of the Assessee is allowed

ITA 189/DDN/2019[2014-2015]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-2015

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Shri Pritpal Singh, Vs. Acit, 71, Guru Road, Circle-2, Dehradun Dehradun (Appellant) (Respondent) Pan: Ahkps3632F Assessee By : Shri Savyasachi Kumar Sahai, Adv Revenue By: Shri Amar Singh Rana, Sr. Dr Date Of Hearing 22/08/2023 Date Of Pronouncement 15/09/2023

For Appellant: Shri Savyasachi Kumar Sahai, AdvFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 271(1)(c)Section 50CSection 56(2)(vii)

penalty u/s 271(1)(c) of the Act could be levied at an addition which has been made u/s 56(2)(vii)(b) of the Act on a deeming fiction. 3. We have heard the rival submission and perused the material available on record. The Assessee filed original return of income on 29.11.2014 for AY 2014-15 declaring total income

SHIV RATAN EDUCATION SOCIETY,HARIDWAR vs. ITO EXEMPTION WARD, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 184/DDN/2025[2020-21]Status: DisposedITAT Dehradun18 Feb 2026AY 2020-21

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

Section 270ASection 270A(9)(a)Section 9

u/s 270A of the Act, the AO had ignored this fact of claim of application towards capital assets and if the same is considered there would be no deficit in the application of funds up to 85% of the gross receipts. It is further observed that the error of claiming depreciation in the application of funds was inadvertently made

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

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

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

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

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

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

PANDITWARI SADHAN SAHKARI SAMITI LIMITED,DEHRADUN vs. INCOME TAX OFFICER , DEHRADUN

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

ITA 88/DDN/2024[2016-17]Status: DisposedITAT Dehradun02 Apr 2025AY 2016-17

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing)

For Appellant: Shri Sushil Kumar, AdvFor Respondent: Shri A. S. Rana, Sr. DR
Section 115BSection 144Section 147Section 148Section 271(1)Section 69

u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2022 by the Assessing Officer, ITO, Ward-1(1)(2), Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience

PANDITWARI SADHAN SAHKARI SAMITI LIMITED,DEHRADUN vs. INCOME TAX OFFICER, DEHRADUN

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

ITA 87/DDN/2024[2017-18]Status: DisposedITAT Dehradun02 Apr 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing)

For Appellant: Shri Sushil Kumar, AdvFor Respondent: Shri A. S. Rana, Sr. DR
Section 115BSection 144Section 147Section 148Section 271(1)Section 69

u/s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2022 by the Assessing Officer, ITO, Ward-1(1)(2), Dehradun (hereinafter referred to as ‘ld. AO’). 2. Identical issues are involved in all these appeals and hence they are taken up together and disposed of by this common order for the sake of convenience