A2Z INFRA ENGINEERING LIMITED,GURGAON vs. CCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

A2Z MAINTENANCE & ENGINEERING SERVICES LTD.,GURGAON vs. DCIT, CENTRAL CIRCLE-II, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

INFRA ENGINEERS LTD.,GURGAON vs. DCIT, CC-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT- CENTRAL CIRCLE-2, FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

A2Z INFRA ENGINEERING LIMITED,GURGAON vs. DCIT CC-2 , FARIDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

56,00,000/- toward undisclosed income in the statement recorded under Section 132(4) of the Act. Similar to AY 2008-09 supra, the aforesaid amount was included by the assessee in the return of income filed under Section 153A of the Act. The penalty proceedings were initiated on such disclosure made in the ROI, without making any reference

VIJAY SINGH CHAUHAN,NOIDA vs. ITO,WARD-2(5), NOIDA

The appeal of the assessee is hereby dismissed

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishravijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. Pan No: Aeipc4637E Appellant Respondent Assessee By : Sh. Naveen Kumar, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 26.09.2025 Order Per Sudhir Pareek, Jm: The Aforetitled Appeal Has Been Preferred Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter, In Short, ‘Cit(A)’] Dated 17.07.2023 For Ay 2015-16, By Which Appeal Of The Assessee Was Dismissed.

penalty proceedings u/s 271(1)(c) is being initiated separately. 14. While deciding the appeal, the Learned CIT(A) observed that the action of the Learned AO in treating the interest income of Rs 13,43,02,195/- as assessed u/s 56(2)(viii) of the Act deserves to be upheld, relevant extract thereof as under: “5.1 During the course

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

2. FACTUAL MATRIX 2.1 The assessee had filed applications under Rule 27 of the ITAT Rules raising the issue of "defective notice" claiming that the penalty notice under Section 274 read with Section 271(1)(c) did not specify the particular charge. 2.2 The Tribunal in para 4 of its order dated 07/09/2025( sic correct date 03.09.2025) has noted that

ADDL. CIT, NEW DELHI vs. M/S. PHI SEEDS PVT. LTD., HYDERABAD

The appeals of the Revenue are dismissed and both the Rule 27 application of the assessee are allowed for A

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

2. FACTUAL MATRIX 2.1 The assessee had filed applications under Rule 27 of the ITAT Rules raising the issue of "defective notice" claiming that the penalty notice under Section 274 read with Section 271(1)(c) did not specify the particular charge. 2.2 The Tribunal in para 4 of its order dated 07/09/2025( sic correct date 03.09.2025) has noted that

POTENT FOODS PRIVATE LIMTED,FARIDABAD vs. ITO WARD-2(1), FARIDABAD

In the result, appeal of the Assessee is allowed

Bench: Shri R.K. Panda

penalty proceedings u/s 271(l)(c) are being initiated for furnishing inaccurate particulars of the income on the above account. Accordingly, notice u/s 274 read with section 271(l)(c) of the Act, is being issued separately to the appellant. The AO is directed to give appeal effect on this account and issue demand notice u/s

ARUN DWIVEDI,NEW DELHI vs. ACIT, CIRCLE-9(2), NEW DELHI

In the result, the appeal of the assessee is allowed

penalty proceedings u/s 271(1)(c) of the Act is\ninitiated separately for failure to disclose the true particulars of\nincome as mentioned above.”\nAggrieved with the said order, the assessee preferred an appeal\nbefore the Ld. CIT(A). However, the Ld. CIT(A) confirmed the action of the\nAO in computing the Long Term Capital Gain of Rs.17

ABHINAV INTERNATIONAL PVT. LTD.,,NEW DELHI vs. DCIT CIRCLE-1(1), NEW DELHI

In the result, appeal of appellant bearing Appeal

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

Section 56(2)(viib) is an anti abuse provision and any addition u/s. 56(2)(viib) is liable for penalty u/s. 271

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

271(1)(c) of the Act. Accordingly, ground Nos. 1, 4, 6 and 7 raised by the assessee are hereby allowed." xi) 179 taxmann.com 421(Mumbai- Trib.) dated 13.10.2025 Bharatkumar Jaishinh vs. ITO (pages 1-5 of JPB) 26 xiii) ITA No. 1285/Ahd/2025 dated 30.10.2025 Krunal Sanghvi vs. ITO (pages 6-12 of JPB) xiv) ITA No. 1054/Bang/2024 dated

ABHIRVEY PROJECTS PRIVATE LIMITED,NEW DELHI vs. ACIT CIRCLE-1(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

56(2)(viib) is upheld in the instant case. Ground No. 1 is decided against the appellant. 7.7 Ground No. 2: In this ground of appeal the appellant has objected to initiation of penalty u/s 271(1 )(c). This ground of appeal is premature and not adjudicated. 7.8 Ground No. 3, 4 & 5: In this ground of appeal the appellant

GOPESH FABRICS PVT. LTD.,BALLABHGARH vs. ITO WARD-1(3) , FARIDABAD

In the result, Appeals in ITA No

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita No.84/Del/2021, A.Y.2016-17)

section 56(2)(viib) of the Acton protective basis and rejecting the valuation report furnished under Rule 11UA(2)(b) of Income Tax Rules, 1962 i.e., Discounted Cash Flow Method. 3. That the Ld. CIT(A) has grossly erred in law as well as on facts in sustaining addition u/s 68 of the Act and enhancing the income of appellant

VIDHI CINEMAS PVT.LTD.,HARYANA vs. ITO WARD-2(5), FARIDABAD

In the result, Appeals in ITA No

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita No.84/Del/2021, A.Y.2016-17)

section 56(2)(viib) of the Acton protective basis and rejecting the valuation report furnished under Rule 11UA(2)(b) of Income Tax Rules, 1962 i.e., Discounted Cash Flow Method. 3. That the Ld. CIT(A) has grossly erred in law as well as on facts in sustaining addition u/s 68 of the Act and enhancing the income of appellant

PINGASH MARKETING PRIVATE LIMITED,BALLABHGARH vs. ITO WARD-2(1), FARIDABAD

In the result, Appeals in ITA No

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita No.84/Del/2021, A.Y.2016-17)

section 56(2)(viib) of the Acton protective basis and rejecting the valuation report furnished under Rule 11UA(2)(b) of Income Tax Rules, 1962 i.e., Discounted Cash Flow Method. 3. That the Ld. CIT(A) has grossly erred in law as well as on facts in sustaining addition u/s 68 of the Act and enhancing the income of appellant

SHANTA BLANKETS PVT. LTD.,HARYANA vs. ITO WARD-2(3) , FARIDABAD

In the result, Appeals in ITA No

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.Ita No.84/Del/2021, A.Y.2016-17)

section 56(2)(viib) of the Acton protective basis and rejecting the valuation report furnished under Rule 11UA(2)(b) of Income Tax Rules, 1962 i.e., Discounted Cash Flow Method. 3. That the Ld. CIT(A) has grossly erred in law as well as on facts in sustaining addition u/s 68 of the Act and enhancing the income of appellant