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51 results for “penalty u/s 271”+ Section 928clear

Sorted by relevance

Mumbai66Delhi51Jaipur10Kolkata7Guwahati5Chennai5Hyderabad4Pune4Bangalore2Surat1

Key Topics

Addition to Income22Section 6815Section 914Section 44B14Double Taxation/DTAA12Search & Seizure12Deduction10Section 143(3)9Section 10A

HINDUSTAN COCA-COLA BEVERAGES PVT. LTD.,NEW DELHI vs. JCIT, SPECIAL RANGE- 4, NEW DELHI

In the result, Appeals filed by the Assessee in ITA No

ITA 2315/DEL/2019[2012-13]Status: DisposedITAT Delhi05 Mar 2024AY 2012-13

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

penalty proceedings under section 271(1)(c) are being initiated separately. (Addition of Rs. 2,25,51,980/-) 16. The Ld. CIT(A) while confirming the said addition for A.Y 2011-12 held as under:- “4.4.3.2. The submissions of the appellant have been considered and are not found to be tenable. The case laws cited have also been considered

HINDUSTAN COCA-COLA BEVERAGES PVT. LTD.,NEW DELHI vs. ADDLCIT, SPECIAL RANGE-4, NEW DELHI

In the result, Appeals filed by the Assessee in ITA No

ITA 6506/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Mar 2024AY 2013-14

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

penalty proceedings under section 271(1)(c) are being initiated separately. (Addition of Rs. 2,25,51,980/-) 16. The Ld. CIT(A) while confirming the said addition for A.Y 2011-12 held as under:- “4.4.3.2. The submissions of the appellant have been considered and are not found to be tenable. The case laws cited have also been considered

Showing 1–20 of 51 · Page 1 of 3

9
Penalty8
Section 9(1)(vii)7
Section 2717

ADDL. CIT, SPECIAL RANGE- 4, NEW DELHI vs. HINDUSTAN COCA-COLA BEVERAGES PVT. LTD., NEW DELHI

In the result, Appeals filed by the Assessee in ITA No

ITA 5903/DEL/2018[2011-12]Status: DisposedITAT Delhi05 Mar 2024AY 2011-12

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

penalty proceedings under section 271(1)(c) are being initiated separately. (Addition of Rs. 2,25,51,980/-) 16. The Ld. CIT(A) while confirming the said addition for A.Y 2011-12 held as under:- “4.4.3.2. The submissions of the appellant have been considered and are not found to be tenable. The case laws cited have also been considered

ADDL. CIT, SPECIAL RANGE- 4, NEW DELHI vs. HINDUSTAN COCA-COLA BEVERAGES PVT. LTD., NEW DELHI

In the result, Appeals filed by the Assessee in ITA No

ITA 6296/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Mar 2024AY 2013-14

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

penalty proceedings under section 271(1)(c) are being initiated separately. (Addition of Rs. 2,25,51,980/-) 16. The Ld. CIT(A) while confirming the said addition for A.Y 2011-12 held as under:- “4.4.3.2. The submissions of the appellant have been considered and are not found to be tenable. The case laws cited have also been considered

HINDUSTAN COCA-COLA BEVERAGES PVT. LTD.,NEW DELHI vs. ADDL. CIT, SPECIAL RANGE- 4, NEW DELHI

In the result, Appeals filed by the Assessee in ITA No

ITA 5925/DEL/2018[2011-12]Status: DisposedITAT Delhi05 Mar 2024AY 2011-12

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

penalty proceedings under section 271(1)(c) are being initiated separately. (Addition of Rs. 2,25,51,980/-) 16. The Ld. CIT(A) while confirming the said addition for A.Y 2011-12 held as under:- “4.4.3.2. The submissions of the appellant have been considered and are not found to be tenable. The case laws cited have also been considered

MOTOROLA SOLUTIONS INDIA PVT. LTD.,GURGAON vs. ACIT, GURGAON

In the result, the appeal being ITA No

ITA 3641/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

penalty proceedings u/s 271(1)(c) which is premature at this stage and accordingly, the same is dismissed as such. 21. Ground No.7 is general in nature, hence the same is dismissed as such. 22. In the result, the appeal filed by the assessee being ITA No.4789/Del/2014 for AY 2005-06 is partly allowed. 23. The assessee has filed appeal

DCIT, GURGAON vs. M/S. MOTOROLA INDIA PVT. LTD., GURGAON

In the result, the appeal being ITA No

ITA 3646/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

penalty proceedings u/s 271(1)(c) which is premature at this stage and accordingly, the same is dismissed as such. 21. Ground No.7 is general in nature, hence the same is dismissed as such. 22. In the result, the appeal filed by the assessee being ITA No.4789/Del/2014 for AY 2005-06 is partly allowed. 23. The assessee has filed appeal

M/S. MOTOROLA SOLUTIONS INDIA PRIVATE LIMITED,GURGAON vs. ACIT, GURGAON

In the result, the appeal being ITA No

ITA 4789/DEL/2014[2005-06]Status: DisposedITAT Delhi16 May 2025AY 2005-06

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

penalty proceedings u/s 271(1)(c) which is premature at this stage and accordingly, the same is dismissed as such. 21. Ground No.7 is general in nature, hence the same is dismissed as such. 22. In the result, the appeal filed by the assessee being ITA No.4789/Del/2014 for AY 2005-06 is partly allowed. 23. The assessee has filed appeal

M/S COLT TECHNOLOGY SERVICES (I) PVT LTD,NEW DELHI vs. DCIT, NEW DELHI

In the result, both the ITA No

ITA 536/DEL/2015[2010-11]Status: DisposedITAT Delhi13 Apr 2022AY 2010-11

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

Section 10ASection 143(3)Section 144C

penalty proceedings under section 271(l)(c) of the Act.” 3. Brief facts of the case are that, the assessee Company is incorporated in India on April 1, 2004 and is a part of the Colt Group of Companies (‘Colt Group’) and provides Information Technology Enabled Services (‘ITES’) and contract software development (‘CSD’) solutions to its associated enterprises

COLT TECHNOLOGY SERVICES INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the ITA No

ITA 1908/DEL/2017[2012-13]Status: DisposedITAT Delhi13 Apr 2022AY 2012-13

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

Section 10ASection 143(3)Section 144C

penalty proceedings under section 271(l)(c) of the Act.” 3. Brief facts of the case are that, the assessee Company is incorporated in India on April 1, 2004 and is a part of the Colt Group of Companies (‘Colt Group’) and provides Information Technology Enabled Services (‘ITES’) and contract software development (‘CSD’) solutions to its associated enterprises

MODI ENTERTAINMENT LTD vs. DCIT CIRCLE 5 (1),

In the result, the appeal of the assessee on this ground is dismissed

ITA 3051/DEL/2007[2001-2002]Status: DisposedITAT Delhi12 Apr 2024AY 2001-2002

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Rohit Garg, AdvFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 10(33)Section 115JSection 143(3)Section 14ASection 2Section 4

928/- has to be added to the net profit for computation of the book profit as per the express provisions of sub-section 2 of section 115JB.  The facts and circumstances of the case laws relied by the assessee are different from the instant case. 4.1 In proceedings before me appellant has filed a detailed written submission on this issue

SARIKA TYAGI,GHAZIBAD vs. DCIT, CENTRAL CIRCLE, GHAZAIBAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1414/DEL/2022[2016-17]Status: DisposedITAT Delhi10 Oct 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

penalty proceedings will also be issued and Petitioner will have to endure that also. 9. In view of the peculiar facts and circumstances of the case, we decided to entertain this petition under Article 226 of the Constitution of India. 10. In the order dated 23rd July 2022 passed under Section 148A(d) of the Act, it records Petitioner

NAVEEN TYAGI,GHAZIABAD vs. DCIT, CENTRAL CIRCLE , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1412/DEL/2022[2016-17]Status: DisposedITAT Delhi10 Oct 2024AY 2016-17

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

penalty proceedings will also be issued and Petitioner will have to endure that also. 9. In view of the peculiar facts and circumstances of the case, we decided to entertain this petition under Article 226 of the Constitution of India. 10. In the order dated 23rd July 2022 passed under Section 148A(d) of the Act, it records Petitioner

DCIT CENTRAL CIRCLE , GHAZIABAD vs. YOGENDER SINGH , GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1387/DEL/2022[2017-18]Status: DisposedITAT Delhi10 Oct 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

penalty proceedings will also be issued and Petitioner will have to endure that also. 9. In view of the peculiar facts and circumstances of the case, we decided to entertain this petition under Article 226 of the Constitution of India. 10. In the order dated 23rd July 2022 passed under Section 148A(d) of the Act, it records Petitioner

DCIT, CENTRAL CIRCLE, GHAZIABAD vs. SUSHIL TYAGI, DELHI

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1386/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Oct 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

penalty proceedings will also be issued and Petitioner will have to endure that also. 9. In view of the peculiar facts and circumstances of the case, we decided to entertain this petition under Article 226 of the Constitution of India. 10. In the order dated 23rd July 2022 passed under Section 148A(d) of the Act, it records Petitioner

YOGENDER SINGH,GHAZIABAD vs. DCIT, CENTRAL CIRCLE, GHAZIABAD

Accordingly, Ground No. 2 raised by the revenue is dismissed

ITA 1413/DEL/2022[2017-18]Status: DisposedITAT Delhi10 Oct 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumardcit, Vs. Sushil Tyagi, Central Circle, A-2, Ganpati Ghaziabad Apartments, Civil Lines, New Delhi (Appellant) (Respondent) Pan:Aejpt6739A Dcit, Vs. Yogender Singh, Central Circle, J-6A, Sector-23, Ghaziabad Sanjay Nagar, Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Yogender Singh, Vs. Dcit, J-6A, Sector-23, Central Circle, Sanjay Nagar, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Bgcos8548E Naveen Tyagi, Vs. Dcit, G-302, Vvip Central Circle, Addresses, Raj Nagar Ghaziabad Extention, Ghaziabad (Appellant) (Respondent) Pan:Admpt6420A Sarika Tyagi, Vs. Dcit, H-100, Patel Nagar,- Central Circle, 3, Ghaziabad Ghaziabad (Appellant) (Respondent) Pan:Afapt5986P Assessee By : Shri Rajeev Khandelwal, Ca Shri Gagan Khandelwal, Adv Shri Jaind Jaiswal, Adv Revenue By: Ms. Sapna Bhatia, Cit Dr Date Of Hearing 23/08/2024 Date Of Pronouncement /10/2024

For Appellant: Shri Rajeev Khandelwal, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 132Section 143(2)Section 68

penalty proceedings will also be issued and Petitioner will have to endure that also. 9. In view of the peculiar facts and circumstances of the case, we decided to entertain this petition under Article 226 of the Constitution of India. 10. In the order dated 23rd July 2022 passed under Section 148A(d) of the Act, it records Petitioner

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

In the result, the appeal of the assessee is allowed

ITA 9400/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Dec 2022AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

For Appellant: Shri Mohit Gupta, CAFor Respondent: Shri Bhagwati Charan, Sr.DR
Section 143(3)Section 56(2)(viib)

928 28,95,750 -93,84,025 3,96,48,32 5 0.10 0.10 0.10 0.10 0.10 0.10 Discount rate (10%) Discount factor 0.91 0 83 0.75 1.00 0.68 0.62 PV of Future cash inflow -19,00,000 -7,96,656 -25,446 19,69,110 -58,18,096 3,60,79,97 6 I.T.A. No.9400/Del/2019 13 Total

GRUNER INDIA PVT. LTD.,NEW DELHI vs. ACIT, CIRCLE- 10(2), NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 4062/DEL/2019[2012-13]Status: DisposedITAT Delhi03 Jul 2023AY 2012-13

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Usita No. 4062/Del/2019 : Asstt. Year : 2012-13 M/S Gruner India Pvt. Ltd., Vs Acit, 15 Dsidc, Okhla Industrial Area, Circle-10(2), Phase-Ii, Scheme-1, New Delhi New Delhi-110020 (Appellant) (Respondent) Pan No. Aadcg2938H Assessee By : Sh. Pancham Sethi, Ca Revenue By : Sh. Mrinal Kumar Das, Sr. Dr Date Of Hearing: 05.04.2023 Date Of Pronouncement: 03.07.2023 Order Per Dr. B. R. R. Kumar: The Present Appeal Has Been Filed By The Assessee Against The Order Dated Xx.02.2019 Passed By The Ao U/S 254/143(3) R.W.S. 144C Of The Income Tax Act, 1961. 2. Following Grounds Have Been Raised By The Assessee:

For Appellant: Sh. Pancham Sethi, CAFor Respondent: Sh. Mrinal Kumar Das, Sr. DR
Section 234BSection 254Section 271(1)(c)Section 92C

penalty proceedings u/s 271(1)(c).” 3. Grunder India Pvt. Ltd. is incorporated in October 2008 and started its operations in November 2009 and is engaged in manufacturing of Latching relays, Solenoids and Actuators specifically used in electrical meters. Gruner India is a joint venture of Gruner AG, Germany in India. The assessee enjoys the exclusive rights to manufacture

DSD NOELL GMBH ,NEW DELHI vs. DCIT CIRCLE-1(2)(2) INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 1619/DEL/2022[2018-19]Status: DisposedITAT Delhi21 Nov 2023AY 2018-19

Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 271Section 44BSection 9Section 9(1)(vii)

penalty proceedings under section 271 (1 )(c) of the Act, as initiated by the Learned Associate Director of Income - tax (Ld. ADIT), provisions of which are not attracted on the facts and circumstances of the case; 10. That the appellant may be allowed to add, supplement, revise, amend grounds as raised hereinabove. 1. That the order of the Learned Commissioner

DSD NOELL GMBH,NEW DELHI vs. DCIT (INTERNATIONAL TAXATION), NEW DELHI

In the result, the appeals of the assessee are allowed

ITA 3186/DEL/2016[2011-12]Status: DisposedITAT Delhi21 Nov 2023AY 2011-12

Bench: SHRI CHALLA NAGENDRA PRASAD (Judicial Member), SHRI M. BALAGANESH (Accountant Member)

Section 271Section 44BSection 9Section 9(1)(vii)

penalty proceedings under section 271 (1 )(c) of the Act, as initiated by the Learned Associate Director of Income - tax (Ld. ADIT), provisions of which are not attracted on the facts and circumstances of the case; 10. That the appellant may be allowed to add, supplement, revise, amend grounds as raised hereinabove. 1. That the order of the Learned Commissioner