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113 results for “penalty u/s 271”+ Section 244A(1)clear

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Key Topics

Section 143(3)68Addition to Income62Section 271(1)(c)51Section 144C48Transfer Pricing40Section 14739Penalty35Comparables/TP31Section 234B

BHARAT SANCHAR NIGAM LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeals of the assessee are allowed

ITA 6459/DEL/2012[2009-10]Status: DisposedITAT Delhi13 May 2016AY 2009-10

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2005-06 Ay: 2009-10

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri Ravi Jain, CIT DR
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 80I

271(1)(c) of the Act was not imposable on claims made but negated by a subsequent amendment. 5. The Ld. DR placed reliance on the order of the Assessing Officer and submitted that the penalty had been imposed correctly. 6. We have heard the rival submissions and have perused the material on record. As far as the penalty

Showing 1–20 of 113 · Page 1 of 6

28
Double Taxation/DTAA28
Section 92C27
Disallowance26

DCIT, NEW DELHI vs. M/S. BHARAT SANCHAR NIGAM LTD., NEW DELHI

The appeals of the assessee are allowed

ITA 5916/DEL/2012[2009-10]Status: DisposedITAT Delhi13 May 2016AY 2009-10

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2005-06 Ay: 2009-10

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri Ravi Jain, CIT DR
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 80I

271(1)(c) of the Act was not imposable on claims made but negated by a subsequent amendment. 5. The Ld. DR placed reliance on the order of the Assessing Officer and submitted that the penalty had been imposed correctly. 6. We have heard the rival submissions and have perused the material on record. As far as the penalty

BHARAT SANCHAR NIGAM LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeals of the assessee are allowed

ITA 2196/DEL/2012[2005-06]Status: DisposedITAT Delhi13 May 2016AY 2005-06

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2005-06 Ay: 2009-10

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri Ravi Jain, CIT DR
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 80I

271(1)(c) of the Act was not imposable on claims made but negated by a subsequent amendment. 5. The Ld. DR placed reliance on the order of the Assessing Officer and submitted that the penalty had been imposed correctly. 6. We have heard the rival submissions and have perused the material on record. As far as the penalty

ACIT, NEW DELHI vs. M/S. BHARAT SANCHAR NIGAM LTD., NEW DELHI

The appeals of the assessee are allowed

ITA 2799/DEL/2012[2005-06]Status: DisposedITAT Delhi13 May 2016AY 2005-06

Bench: Shri S.V. Mehrotra & Shri Sudhanshu Srivastavaay: 2005-06 Ay: 2009-10

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri Ravi Jain, CIT DR
Section 115JSection 143(3)Section 271(1)Section 271(1)(c)Section 80I

271(1)(c) of the Act was not imposable on claims made but negated by a subsequent amendment. 5. The Ld. DR placed reliance on the order of the Assessing Officer and submitted that the penalty had been imposed correctly. 6. We have heard the rival submissions and have perused the material on record. As far as the penalty

PR. COMMISSIONER OF INCOME TAX -7 vs. SUMITOMO CORPORATION INDIA (P) LTD.

ITA/52/2023HC Delhi02 Sept 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

271(1)(c) of the Act issued by AO 17.06.2019 Annexure P-12 on pg. 205 of WP 17.06.2019 Annexure P- 12 on pg. 151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MICROSOFT INDIA ( R & D) PVT. LTD.

ITA/993/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

271(1)(c) of the Act issued by AO 17.06.2019 Annexure P-12 on pg. 205 of WP 17.06.2019 Annexure P- 12 on pg. 151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice

THE PR. COMMISSIONER OF INCOME TAX -6 vs. MARUTI SUZUKI INDIA LTD.

ITA/995/2019HC Delhi02 Mar 2020

Bench: HON'BLE MR. JUSTICE VIPIN SANGHI,HON'BLE MR. JUSTICE SANJEEV NARULA

271(1)(c) of the Act issued by AO 17.06.2019 Annexure P-12 on pg. 205 of WP 17.06.2019 Annexure P- 12 on pg. 151 of WP 17.06.2019 Annexure P- 10 on pg. 329 of WP 17.06.2019 Annexure P-10 on pg. 233 of WP 17.06.2019 Annexure P-12 on pg. 299 of WP 11 Response to sec 274 notice

NEW SAMRAT METALS CO. PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the Assessee allowed

ITA 2470/DEL/2017[2012-13]Status: DisposedITAT Delhi24 Jan 2020AY 2012-13

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms. Rakhi Vimal, Sr. DR
Section 271(1)Section 271(1)(c)

section 271(1)(c) of the I.T. Act, 1961. 2 ITA.No.2470/Del./2017 M/s. New Samrat Metals Co. Pvt. Ltd., New Delhi. 2. The assessee has raised the following grounds of appeal : “1. That the CIT (A) is erred under the law while partly confirming the order of A.O., imposing the penalty u/s 271(1

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT INTERNATIONAL TAXATION CIRCLE 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2091/DEL/2023[2020-21]Status: DisposedITAT Delhi03 May 2024AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order passed by the Ld. AO under s. 143(3) read with s. 144C(13) of the Act, taxing the receipts amounting to Rs. 7,94,63,248/- under s. 44BB

COMPUTER MODELLING GROUP LIMITED,CANADA vs. ACIT, CIRCLE-1(2)(1), INT. TAXATION, NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2305/DEL/2022[2019-20]Status: DisposedITAT Delhi03 May 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order passed by the Ld. AO under s. 143(3) read with s. 144C(13) of the Act, taxing the receipts amounting to Rs. 7,94,63,248/- under s. 44BB

COMPUTER MODELLING GROUP LIMITED,CANADA vs. DCIT CIRCLE INTERNATIONAL TAXATION 1(2)(1), NEW DELHI

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2090/DEL/2023[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order passed by the Ld. AO under s. 143(3) read with s. 144C(13) of the Act, taxing the receipts amounting to Rs. 7,94,63,248/- under s. 44BB

M/S. LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT (INTERNATIONAL TAXATION), NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 1946/DEL/2017[2007-08]Status: HeardITAT Delhi02 Sept 2019AY 2007-08

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 3327/DEL/2018[2013-14]Status: HeardITAT Delhi02 Sept 2019AY 2013-14

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- NOIDA, INTERNATIONAL TAXATION, NOIDA

In the result all the 9 appeals filed by the assessee are allowed with above direction for statistical purposes

ITA 6916/DEL/2017[2008-09]Status: HeardITAT Delhi02 Sept 2019AY 2008-09

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri G. K. Dhall, CIT DR
Section 143(3)Section 147

244A of the Act. 12. That the AO/DRP has grossly erred in law and facts in initiating the penalty under section 271(l)(c) of the Act and alleging that the Appellant has concealed the true and correct particulars of its taxable income and furnished inaccurate particulars of its income. 13. That the AO/ DRP has grossly erred

KEYSTONE DEVELOPERS PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 5, NEW DELHI

Appeal of the assessee is allowed

ITA 2558/DEL/2018[2013-14]Status: DisposedITAT Delhi14 Oct 2021AY 2013-14

Bench: Ms Suchitra Kamble & Sh. Prashant Maharishi

Section 14ASection 244ASection 27(1)(c)Section 271(1)(c)Section 274

Section 271(1)(c) the penalty proceedings had been initiated. Besides that the Ld AR submitted that on merit penalty has been imposed due to impugned addition relating to interest u/s 244A

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

ITA 2610/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Sept 2020AY 2013-14

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

For Appellant: Shri Kanchan Kaushal, CAFor Respondent: Shri G.K. Dhall, CIT-DR
Section 143(3)Section 144C(1)Section 244ASection 271(1)(c)Section 9(1)(vi)

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed by the Learned

TURNER BROADCASTING SYSTEM ASIA PACIFIC INC.,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

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

ITA 4087/DEL/2016[2012-13]Status: DisposedITAT Delhi30 Sept 2020AY 2012-13

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

For Appellant: Shri Kanchan Kaushal, CAFor Respondent: Shri G.K. Dhall, CIT-DR
Section 143(3)Section 144C(1)Section 244ASection 271(1)(c)Section 9(1)(vi)

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed by the Learned

TURNER BROADCASTING SYSTEM ASIA PACIFIC, INC.,NEW DELHI vs. DCIT, NEW DELHI

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

ITA 631/DEL/2015[2010-11]Status: DisposedITAT Delhi30 Sept 2020AY 2010-11

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

For Appellant: Shri Kanchan Kaushal, CAFor Respondent: Shri G.K. Dhall, CIT-DR
Section 143(3)Section 144C(1)Section 244ASection 271(1)(c)Section 9(1)(vi)

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed by the Learned

TURNER BROADCASTING SYSTEMASIA PACIFIC, INC.,NEW DELHI vs. DDIT, NEW DELHI

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

ITA 1343/DEL/2014[2009-10]Status: DisposedITAT Delhi30 Sept 2020AY 2009-10

Bench: Shri Amit Shukla & Shri B.R.R. Kumar

For Appellant: Shri Kanchan Kaushal, CAFor Respondent: Shri G.K. Dhall, CIT-DR
Section 143(3)Section 144C(1)Section 244ASection 271(1)(c)Section 9(1)(vi)

244A of the Act. 6. That on the facts and circumstances of the case and in law, the Ld.AO erred in initiating penalty proceedings under Section 271(1)(c) of the Act. Grounds of Appeal for AY 2012-13 1. That on the facts and circumstances of the case and in law, the impugned assessment order passed by the Learned

MAHAVIR PRASAD GUPTA,DELHI vs. ACIT, NEW DELHI

In the result the appeal of the assessee is allowed

ITA 6580/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jul 2018AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishimahavir Prasad Gupta, Vs. Acit, E-165, Shastri Nagar, Circle-38(1), Delhi New Delhi Pan: Agwpg5362M (Appellant) (Respondent)

For Appellant: Shri Ved Jain, AdvFor Respondent: None
Section 143(3)Section 244ASection 271(1)(c)

section 271(1)(c) of the Income Tax Act, 1961 is bad, both in the eye of law and on the facts. 2. On the facts and circumstances of the case, the Id. CIT(A) has erred, both on facts and in law, in confirming the levy of penalty amounting to Rs.17,01,220/-. 3. On the facts and circumstances