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4,772 results for “penalty u/s 271”+ Section 8clear

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Key Topics

Section 271(1)(c)101Addition to Income77Penalty60Section 234E42Section 143(3)37Section 27129Section 6827Disallowance24Natural Justice

DCIT, CIRCLE 22(2), NEW DELHI, NEW DELHI vs. SAHIL VACHANI, DELHI

Appeal of the Revenue stands dismissed

ITA 2604/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy& Shriavdhesh Kumar Mishraआअसं.2604/िद"ी/2023(िन.व. 2016-17)

For Appellant: S/Shri Anuj Garg & Narpat Singh, Sr.DRFor Respondent: S/Shri Rohan Khare & Priyam
Section 271(1)(c)Section 54F

penalty provision u/s. 271(1)(c) are not attracted. The Hon’ble Apex Court in the case of CIT vs. Reliance Petroproducts Pvt. Ltd. 322 ITR 158 (SC) held: ‘It was tried to be suggested that Section 14A of the Act specifically excluded the deductions in respect of the expenditure incurred by the assessee in relation to income which does

DCIT-CENTRAL CIRCLE-2, FARIDABAD vs. A2Z INFRA ENGINEERS LTD., GURGAON

In the result, the appeal of the assessee is allowed

Showing 1–20 of 4,772 · Page 1 of 239

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23
Section 69A22
Section 14822
Section 153A21
ITA 812/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 2631/DEL/2018[2008-09]Status: DisposedITAT Delhi28 Mar 2023AY 2008-09

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 943/DEL/2019[2013-14]Status: DisposedITAT Delhi28 Mar 2023AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

DCIT CC-2 , FARIDABAD vs. A2Z MAINTENANCE AND ENGINEERING SERVICES LTD., GURGAON

In the result, the appeal of the assessee is allowed

ITA 811/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 941/DEL/2019[2011-12]Status: DisposedITAT Delhi28 Mar 2023AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 939/DEL/2019[2009-10]Status: DisposedITAT Delhi28 Mar 2023AY 2009-10

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 940/DEL/2019[2010-11]Status: DisposedITAT Delhi28 Mar 2023AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

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

In the result, the appeal of the assessee is allowed

ITA 942/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Mar 2023AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharma

For Appellant: Ms. Ritu Kamal KishoreFor Respondent: Shri P. Praveen Sidharth, CIT-DR
Section 132Section 132(4)Section 153ASection 271(1)(c)Section 274

penalty proceedings u/s 271(1)(c) are initiated separately’ do not comply with the meaning of the word ‘direction’ as contemplated in amended section 271(1B) of the Act. 9.2.8 In view of the above judicial pronouncements, both pre and post insertion of S. 271(1B), the position of law emerges is that for initiation of I.T.As No.2631/Del/2018

SMT. SUMAN LAKHANI,NEW DELHI vs. ACIT, FARIDABAD

In the result, the penalty amounting to Rs

ITA 857/DEL/2016[2008-09]Status: DisposedITAT Delhi13 Sept 2019AY 2008-09

Bench: Shri Amit Shukla & Shri Anadee Nath Misshra

For Appellant: Shri Gaurav Madan, CAFor Respondent: Shri Janardan Das, Sr. DR
Section 143(3)Section 271(1)(c)Section 36

8) TMI 1145 - Supreme Court. The Apex Court held that High Court order confirmed (2015) (11) TMI 1620 (Supra) - Karnataka High Court. Notice issued by AO under section 274 read with section 271(l)(c) to be bad in law as it did not specify which limb of Section 27 l(l)(c) of the Act, the penalty proceedings

ACIT, NEW DELHI vs. M/S. RESURGERE MINES AND MINERALS INDIA LTD., MUMBAI

In the result, the appeal filed by the Revenue is dismissed

ITA 1531/DEL/2017[2008-09]Status: DisposedITAT Delhi18 Jul 2019AY 2008-09

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

For Appellant: Shri Ved Jain, CA and Shri Ashish Jain, CAFor Respondent: Shri Surender Pal, Sr. DR
Section 143(3)Section 14ASection 271(1)(c)

8. Secondly, own funds being more than the investment made by the assessee no disallowance under section 14A is called for. In the present case, own funds are of Rs. 22,591 Lacs whereas investment is RS.191 0 ITA No.- 1531/Del/2017. M/s Resurgere Mines and Minerals India Ltd. Lacs, therefore, disallowance under section 14A cannot be made. In this regard

GE JENBACHER GMBH & CO. OHG,GURGAON vs. DCIT, CIRCLE- 1(3)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 692/DEL/2019[2004-05]Status: DisposedITAT Delhi12 Apr 2019AY 2004-05

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GE PACKAGED POWER INC.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1(3)(1), NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 765/DEL/2019[2001-02]Status: DisposedITAT Delhi12 Apr 2019AY 2001-02

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GE JENBACHER GMBH & CO. OHG,GURGAON vs. DCIT, CIRCLE- 1(3)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 757/DEL/2019[2008-09]Status: DisposedITAT Delhi12 Apr 2019AY 2008-09

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GE JENBACHER GMBH & CO. OHG,GURGAON vs. ACIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 755/DEL/2019[2006-07]Status: DisposedITAT Delhi12 Apr 2019AY 2006-07

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GE JENBACHER GMBH & CO.,GURGAON vs. DCIT, CIRCLE- 1(3)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 756/DEL/2019[2007-08]Status: DisposedITAT Delhi12 Apr 2019AY 2007-08

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GENERAL ELECTRIC POWER SYSTEMS INC.,GURGAON vs. DCIT, CIRCLE- 1(3)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 693/DEL/2019[2001-02]Status: DisposedITAT Delhi12 Apr 2019AY 2001-02

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

GE PACKAGED POWER INC.,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-1(3)(1), NEW DELHI

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 758/DEL/2019[2004-05]Status: DisposedITAT Delhi12 Apr 2019AY 2004-05

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

ADIT, NEW DELHI vs. GE JENBACHER GMBH & CO., GURGAON

In the result, all the eight appeals are allowed for statistical purposes and all the

ITA 754/DEL/2019[2005-06]Status: DisposedITAT Delhi12 Apr 2019AY 2005-06

Bench: Smt. Beena A. Pillai & Shri Anadee Nath Misshra

8. That on the facts and circumstances of the case and in law, the CIT(A) erred in confirming the levy of penalty under Section 271(1)(c) of the Act on the basis of profits attributed to the alleged PE of the Appellant, which was based on estimation, and, therefore, do not tantamount to concealment of income or furnishing

M/S. SPAZE TOWERS PVT. LTD.,GURGAON vs. DCIT, FARIDABAD

In the result, the appeal filed by the Revenue as well as the application filed under Rule 27 of the ITAT Rules by the assessee are dismissed

ITA 2044/DEL/2014[2006-07]Status: DisposedITAT Delhi20 Nov 2018AY 2006-07

Bench: Shri O.P. Kant, Accountnat Member & Shri Kuldip Singh

For Appellant: 1. the Learned CIT(A) has erred in law & facts of the case in sustaining the pen
Section 132Section 132(4)Section 139Section 153ASection 271(1)(c)Section 4

8 ( unaccounted cash of Rs. 5,22,50,000), paragraph 9 (unexplained investment purchase of the property amounting to Rs.8 crore), paragraph 10 (undisclosed cash of Rs.5.225 crores) , paragraph 12 ( undisclosed income in respect of the project amounting to Rs.11,56,54,507/-). 11.8 The Assessing Officer issued show cause notice for levy of penalty under section 271