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10 results for “penalty u/s 271”+ Section 251(1)(a)clear

Sorted by relevance

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Key Topics

Section 44B14Section 914Addition to Income10Section 2637Section 69A6Section 1484Penalty3Section 143(3)2Section 143(1)

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

2
Section 271(1)(c)2
Reopening of Assessment2

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

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

251 Taxman 459 (SC)/[2017] 399 ITR 1 (SC)/[2017] 299 CTR 1 (SC) while deciding the issue of mobilization fees has held that when the contracts are indivisible, it is not appropriate to treat the various receipts of the contract differently. Therefore, material used for performance of contract cannot be treated differently than other consideration received. In fact

MRS. NIDHI YADAV,DEHRADUN vs. ITO, RUDRAPUR

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 117/DDN/2024[2015-16]Status: DisposedITAT Dehradun31 Jul 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.115/Ddn/2024, A.Y. 2013-14 Ita No.117/Ddn/2024, A.Y. 2015-16 Nidhi Yadav, Vs. Income Tax Officer, B-801, Forest Residency, Ward 2(1)(4), Dehradun, Uttarakhand Income Tax Office, Pin Code: 248014 Rudrapur, Uttarakhand Pan: Acapy5157E (Respondent) Appellant By Sh. Mohit Dev, Ca Respondent By Sh. Amarpal Singh, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 31/07/2025 Order Per Avdhesh Kumar Mishra, Am Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

Section 143(1)Section 148Section 271(1)(c)Section 69A

Penalty proceedings u/s. 271(1)(c) of the I.T. Act, 1961 is initiated separately for concealment of particulars of income.” 4.3 Aggrieved with both assessment orders, the assessee filed appeals before the Ld. CIT(A), who dismissed both appeals on the reasoning that the assessee did not pursue these appeals properly and did not controvert the finding

SMT. NIDHI YADAV,DEHRADUN vs. ITO- W-2(1)(4),, RUDRAPUR

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 115/DDN/2024[2013-14]Status: DisposedITAT Dehradun31 Jul 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.115/Ddn/2024, A.Y. 2013-14 Ita No.117/Ddn/2024, A.Y. 2015-16 Nidhi Yadav, Vs. Income Tax Officer, B-801, Forest Residency, Ward 2(1)(4), Dehradun, Uttarakhand Income Tax Office, Pin Code: 248014 Rudrapur, Uttarakhand Pan: Acapy5157E (Respondent) Appellant By Sh. Mohit Dev, Ca Respondent By Sh. Amarpal Singh, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 31/07/2025 Order Per Avdhesh Kumar Mishra, Am Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

Section 143(1)Section 148Section 271(1)(c)Section 69A

Penalty proceedings u/s. 271(1)(c) of the I.T. Act, 1961 is initiated separately for concealment of particulars of income.” 4.3 Aggrieved with both assessment orders, the assessee filed appeals before the Ld. CIT(A), who dismissed both appeals on the reasoning that the assessee did not pursue these appeals properly and did not controvert the finding

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

ITA 69/DDN/2024[2020-21]Status: DisposedITAT Dehradun24 Dec 2025AY 2020-21
Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 251(1)(a)Section 270ASection 80

penalty proceedings u/s 271(1)(c) of the Act which is\npremature at this stage and thus, dismissed.\nPage | 17\nITA No.69/DDN/2024\n24 Ground of appeal No.6 raised by the assessee is with respect to\ncharging of interest u/s 234A whereas the assessee though the return\nof income was filed within the extended due date.\n25. Heard both the parties