SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SMT. SNEH LATA SAWHNEY,NEW DELHI vs. DCIT, NEW DELHI

In the result, ITA.Nos.420, 421, 422, 423, 424

Bench: Shri Anil Chaturvedi & Ms. Astha Chandra

penalty proceedings under section 271(1)(c) of the I,.T. Act, 1961 for the A.Ys. 2006-2007 to 2011-2012. 2. Since common issues are involved in all the above appeals, the appeals were heard together and are being disposed of by the consolidated order for the sake of convenience. First, we cull-out the facts from the quantum

SATYA PRAKASH SHARMA,NEW DELHI vs. ITO WARD - 47(4), NEW DELHI

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

Bench: Sh. Anil Chaturvediita Nos. 7293 & 7294/Del/2019 (Assessment Year : 2015-16) Satya Prakash Sharma Vs. Ito 3051/2, Gali Kalyan Ward – 47(4) Singh, Ram Bazaar, New Delhi New Delhi – 110 006 Pan No. Amfps 0402 H (Appellant) (Respondent) Assessee By Shri Mayank Patwari, C.A. Revenue By Shri Om Prakash, Sr. D.R. Date Of Hearing: 16.06.2022 Date Of Pronouncement: 14.09.2022 Order Per Anil Chaturvedi, Am: These Two Appeals Filed By The Assessee Are Directed Against The Orders Dated 25.06.2019 & 26.06.2019 Passed By The Commissioner Of Income Tax (Appeals)-16, New Delhi Relating To Assessment Year 2015-16 Being Quantum Appeal & Penalty Appeal Respectively.

section 144/143(3) vide order dated 28.12.2017 and determined the total income of the assessee at Rs.17,44,257/-. On such additions, AO also levied the penalty u/s 271(1)(c) of the Act. 4. Aggrieved by the order of AO, assessee carried the matter in appeal before the Ld CIT(A) who vide order dated 25.06.2019 in Appeal No.10068/2018-19

SATYA PRAKASH SHARMA,NEW DELHI vs. ITO WARD - 47(4), NEW DELHI

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

Bench: Sh. Anil Chaturvediita Nos. 7293 & 7294/Del/2019 (Assessment Year : 2015-16) Satya Prakash Sharma Vs. Ito 3051/2, Gali Kalyan Ward – 47(4) Singh, Ram Bazaar, New Delhi New Delhi – 110 006 Pan No. Amfps 0402 H (Appellant) (Respondent) Assessee By Shri Mayank Patwari, C.A. Revenue By Shri Om Prakash, Sr. D.R. Date Of Hearing: 16.06.2022 Date Of Pronouncement: 14.09.2022 Order Per Anil Chaturvedi, Am: These Two Appeals Filed By The Assessee Are Directed Against The Orders Dated 25.06.2019 & 26.06.2019 Passed By The Commissioner Of Income Tax (Appeals)-16, New Delhi Relating To Assessment Year 2015-16 Being Quantum Appeal & Penalty Appeal Respectively.

section 144/143(3) vide order dated 28.12.2017 and determined the total income of the assessee at Rs.17,44,257/-. On such additions, AO also levied the penalty u/s 271(1)(c) of the Act. 4. Aggrieved by the order of AO, assessee carried the matter in appeal before the Ld CIT(A) who vide order dated 25.06.2019 in Appeal No.10068/2018-19

MICROSOFT REGIONAL SALES CORPORATION,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), GURGAON

In the result, the appeal in ITA No

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

penalty proceedings under section 271(l)(c) of the Act against the Appellant. The above grounds of appeal are mutually exclusive and without prejudice to each other. The appellant craves leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal. I.T.A. No. 1135/Del/2017 (A.Y 2013-14) 2. Brief

MICROSOFT REGIONAL SALES CORPORATION,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2(2)(1), GURGAON

In the result, the appeal in ITA No

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

penalty proceedings under section 271(l)(c) of the Act against the Appellant. The above grounds of appeal are mutually exclusive and without prejudice to each other. The appellant craves leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal. I.T.A. No. 1135/Del/2017 (A.Y 2013-14) 2. Brief

MICROSOFT REGIONAL SALES CORPORATION,NEW DELHI vs. ACIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeal in ITA No

Bench: Dr. B. R. R. Kumar & Sh. Yogesh Kumar U.S.

penalty proceedings under section 271(l)(c) of the Act against the Appellant. The above grounds of appeal are mutually exclusive and without prejudice to each other. The appellant craves leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal. I.T.A. No. 1135/Del/2017 (A.Y 2013-14) 2. Brief

ACIT, CIRCLE-13(1), NEW DELHI vs. JALANDHAR AMRITSAR TOLLWAYS LTD, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2015 for AY 2012-13 and 10.03.2025 by the Assessing Officer, DCIT, ITA No.2921 & 3926/Del/2017 ITA Nos.4214 & 3927/Del/2017 M/s. Jalandhar Amritsar Tollways Ltd Circle-13(1), Delhi and DCIT, Circle-4(1), Delhi (hereinafter referred to as ‘ld. AO’). Identical issues are involved

JALANDHAR AMRITSAR TOLLWAYS LTD.,NEW DELHI vs. DCIT, CIRCLE- 13(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2015 for AY 2012-13 and 10.03.2025 by the Assessing Officer, DCIT, ITA No.2921 & 3926/Del/2017 ITA Nos.4214 & 3927/Del/2017 M/s. Jalandhar Amritsar Tollways Ltd Circle-13(1), Delhi and DCIT, Circle-4(1), Delhi (hereinafter referred to as ‘ld. AO’). Identical issues are involved

JALANDHAR AMRITSAR TOLLWAYS LTD.,NEW DELHI vs. DCIT, CIRCLE- 13(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2015 for AY 2012-13 and 10.03.2025 by the Assessing Officer, DCIT, ITA No.2921 & 3926/Del/2017 ITA Nos.4214 & 3927/Del/2017 M/s. Jalandhar Amritsar Tollways Ltd Circle-13(1), Delhi and DCIT, Circle-4(1), Delhi (hereinafter referred to as ‘ld. AO’). Identical issues are involved

JALANDHAR AMRITISAR TOLLWAYS LTD.,,NOIDA vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 31.03.2015 for AY 2012-13 and 10.03.2025 by the Assessing Officer, DCIT, ITA No.2921 & 3926/Del/2017 ITA Nos.4214 & 3927/Del/2017 M/s. Jalandhar Amritsar Tollways Ltd Circle-13(1), Delhi and DCIT, Circle-4(1), Delhi (hereinafter referred to as ‘ld. AO’). Identical issues are involved

COMMISSIONER OF INCOME TAX

penalty u/s 271(1)(c) was initiated. Therefore, we are of the view that surrender should have been accepted as a whole, instead of in piecemeal. The CIT(Appeals) also confirmed the action of the Assessing Officer. In our considered view, the CIT(Appeals) was also not justified in not accepting the claim of the assessee of business profits

KAAJAL AIJAZ ILMI,NEW DELHI vs. ACIT, CENTRAL CIRCLE-20, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.2228 & 2229/Del/2018 & 7004 & 7005/Del/2019 [Assessment Year : 2014-15 & 2015-16 & 2014-15 & 2015-16] Kaajal Aijaz Ilmi, Vs Acit, C/O-Rra Tazindia, D-28, Central Circle-20, South Extension, Part-1, New Delhi New Delhi-110049. Pan-Aabpi4222R Appellant Respondent Appellant By Shri Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Respondent By Ms. Monika Singh, Cit Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 30.07.2025

penalty levied u/s 271(1)(c) of the Act and therefore, they will be taken up after disposing the quantum appeals for these two assessment years. 3. First we take appeal of the assessee in ITA No.2228/Del/2018 [Assessment Year 2014-15]. ITA No.2228/Del/2018 [Assessment Year 2014-15] 4. Brief facts of the case are that a search and seizure operation