JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

u/s 271(1)(c)/271A and 271AAB of the Act have been passed on 12/10/2021 for the years under consideration. Aggrieved by the penalty orders the assessee preferred the Appeals before the CIT(A). The Ld. CIT(A) vide orders dated 29/12/2022 and 26/12/2022 dismissed the Appeals filed by the assessee. As against the orders

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

u/s 271(1)(c)/271A and 271AAB of the Act have been passed on 12/10/2021 for the years under consideration. Aggrieved by the penalty orders the assessee preferred the Appeals before the CIT(A). The Ld. CIT(A) vide orders dated 29/12/2022 and 26/12/2022 dismissed the Appeals filed by the assessee. As against the orders

JAINA MARKETING & ASSOCIATES,DELHI vs. DCIT, CENTRAL CIRCLE-18, DELHI

Accordingly, Appeals filed by the assessee are allowed

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

u/s 271(1)(c)/271A and 271AAB of the Act have been passed on 12/10/2021 for the years under consideration. Aggrieved by the penalty orders the assessee preferred the Appeals before the CIT(A). The Ld. CIT(A) vide orders dated 29/12/2022 and 26/12/2022 dismissed the Appeals filed by the assessee. As against the orders

SAVITA BANSAL,NEW DELHI vs. ITO WARD-35(2), NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

2 3. Briefly stated, the assessee in the instant case filed her return of income declaring total income at Rs.83,67,310/- against the returned income of Rs.8,74,590/-. The assessee in her return of income had shown Rs.1,13,90,000/- as receipt / sale consideration on the sale of property at Laxmi Nagar Delhi whereas total sale consideration

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

u/s 270A of the Act are highly vague in as much as they do not state as to which clause of section 270A(2) of the Act, appellant is alleged to have under-reported income. Infact, even the amount of alleged under-reporting of income has neither been specified and, nor determined in the notice. Also, in the alternative, section

ATMA RAM BUILDERS PRIVATE LIMITED, NEW DELHI,NEW DELHI vs. INCOME TAX OFFICER, CENTRAL CIRCLE 5, NEW DELHI, NEW DELHI

In the result, appeal of the Assessee is allowed in above terms

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

2. Non-Current investments: Rs. 59,53,24,036/- 3. Cash Deposits: Rs. 3,97,06,452/- 4. Purchases: Rs. 4,04,91,936/- 5. Rental Income: Rs.8,86,14,791/- 6. Sales of service: Rs.9,66,05,036/- 7. Aggregate other Income: Rs. 7,13,90,455/-etc., 4. The assessee furnished submissions on various dates to the show

DCIT, CIRCLE- 20(1), NEW DELHI vs. POLYPLEX CORPORATION LIMITED., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Kul Bharat & Shri M.Balaganesh[Assessment Year : 2016-17] Dcit, Vs Polyplex Corporation Limited, Circle-20(1), 40, New Mandakini, Greater New Delhi Kailash, New Delhi-110092. Pan-Aaacp0278J Appellant Respondent Appellant By Shri Vivek Vardhan, Sr.Dr Respondent By Shri Ved Jain, Adv. & Shri Aman Garg, Ca Date Of Hearing 04.04.2024 Date Of Pronouncement 12.04.2024

section 40(a)(i) of the Act; disallowance u/s 35(2)(AB) of the Act at INR 1,76,87,054/- and relief claimed u/s 90 of the Act of INR 24,37,344/- was restricted to NIL. Thereafter, the Assessing Officer (“AO”) initiated penalty proceedings u/s 271

SHRI CHETAN SETH,NEW DELHI vs. ITO, NEW DELHI

The appeals of the assessee are partly allowed

Bench: Shri Satbeer Singh Godara\Nand\Nshri Brajesh Kumar Singh\Nita Nos.1808/Del/2023 & 2983, 2984 & 2985/Del/2015\N[Assessment Years: 2004-05, 2005-06, 2006-07 & 2007-08]\Nshri Chetan Seth,\Nplot No.14, Lcs, Sector-B-1,\Nvasant Kunj,\Nnew Delhi-110070\Npan-Aolps2992A\Nappellant\Nincome Tax Officer,\Nward-15(3),\Nvs New Delhi\Nrespondent\Nappellant By\Nrespondent By\Nshri Arun Kishore, Ca &\Nshri Alok Suri, Ca\Nshri Rajesh Kumar Dhanesta, Sr.\N(Dr)\Ndate Of Hearing\Ndate Of Pronouncement\N28.03.2025\N25.06.2025\Norder\Nper Brajesh Kumar Singh, Am,\Nthese Four Appeals Filed By The Assessee Are Directed Against The\Norder Of Ld. Commissioner Of Income Tax (Appeals)-7, Delhi, Dated\N24.02.2015 For Ay 2004-05, 27.02.2015 For Ay 2005-06, 2006-07 And\N2007-08 Respectively Arising Out Of Assessment Orders Passed U/S 147/144\Nof The Income Tax Act, 1961 (Hereinafter Referred To ‘The Act') Dated\N31.10.2011 For All The Above Assessment Years, Respectively. Since, The\Nissues Are Common & Connected, Hence, These Appeals Were Heard\Ntogether & Are Disposed Of By This Common Order.\N2. First, We Shall Take Up The Ita No.1808/Del/2023 Pertaining To Ay\N2004-05.\N2.

271 (1) (c) of the Act for the above\nadditions were successfully represented by the same previous counsel\nbefore CIT (Appeals). Departmental appeals against the deletion of penalties\nwere dismissed.\n7. Appeals against additions u/s 2 (22) (e) for the three years 2005-06 to 2007-\n08 were also being represented till last year by the same previous counsel.It\nwas

ACIT, CIRCLE-26(2), NEW DELHI vs. VODAFONE WEST LTD., (THEREAFTER MERGED WITH VODAFONE MOBILE SERVICES LTD.),, NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

u/s 271(1)(c) and there has to be a deliberate attempt on part of the assessee to conceal the particulars of income. The Appellant contended that since it had disclosed all the material facts to the AO, it cannot be said that it had concealed particulars of income. However, the AO has observed on this issue and has relied

ACIT, CIRCLE- 26(2), NEW DELHI vs. VODAFONE IDEA LTD. (EARLIER KNWON AS VODAFONE MOBILE SERVICES LTD.), NEW DELHI

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

u/s 271(1)(c) and there has to be a deliberate attempt on part of the assessee to conceal the particulars of income. The Appellant contended that since it had disclosed all the material facts to the AO, it cannot be said that it had concealed particulars of income. However, the AO has observed on this issue and has relied

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(1)(c). As regards the disallowance of interest, it is found that the appellant company has taken interest bearing loan and given it as interest free loan to its I.T.A No.7822/Del/2019 5 sister concerns. The appellant has also

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDL. COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 04,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

271(1)(c) and 271E of the Act. Admittedly, under section 271E(2) of the Act, any penalty under section 271E(1)can only be imposed by the Joint Commissioner of Income-tax ("the Joint CIT").Consequently, the Assessing Officer referred the matter to the Additional Commissioner of Income-tax. 3. A perusal of the order dated March