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856 results for “penalty u/s 271”+ TDSclear

Sorted by relevance

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Key Topics

TDS53Penalty52Addition to Income51Section 271(1)(c)49Section 143(3)44Section 234E42Section 271C41Deduction31Section 20128Disallowance

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 under section 271(1)(c) of the Act. That is not the intendment of the Legislature. Accordingly, Ld. Counsel for the assessee argued that there was a legal principle as propounded by the Apex Court, the claim needs to be seen from the return of income and where such claim was correct at such point of time. Ld. Counsel

HINDUSTAN COCA COLA MARKETING COMPANY PVT. LTD.,GURGAON vs. DCIT, CIRCLE-11(2), NEW DELHI

The appeal is partly allowed and the stay

Showing 1–20 of 856 · Page 1 of 43

...
23
Double Taxation/DTAA23
Section 194C20
ITA 7900/DEL/2018[2006-07]Status: DisposedITAT Delhi27 Feb 2019AY 2006-07

Bench: Shri Kuldip Singh & Shri Anadee Nath Misshra

For Appellant: Sh. Sachit Jolly, AdvFor Respondent: Smt. Aparna Karan, CIT(DR)
Section 250(6)Section 271Section 271(1)(c)Section 274Section 40Section 44A

271(1)(c) of IT Act. The penalty has been levied in respect of disallowances of Rs. 13,97,08,721/- and Rs. 15,07,658/- U/s 40A(i)(a) of IT Act, totaling Rs. 14,12,16,379/-. 3. Aggrieved, the Assessee filed appeal against the aforesaid order dated 23.03.2016, before the Ld. CIT(A). Vide order dated

DCIT, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATE

In the result, all the appeals of the Revenue for the

ITA 1391/DEL/2023[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATE

In the result, all the appeals of the Revenue for the

ITA 1392/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Aug 2023AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1390/DEL/2023[2014-15]Status: DisposedITAT Delhi31 Aug 2023AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1), INT.TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1384/DEL/2023[2005-06]Status: DisposedITAT Delhi31 Aug 2023AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1383/DEL/2023[2004-05]Status: DisposedITAT Delhi31 Aug 2023AY 2004-05

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1389/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Aug 2023AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

ACIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, GURGAON

In the result, all the appeals of the Revenue for the

ITA 441/DEL/2023[2007-08]Status: DisposedITAT Delhi31 Aug 2023AY 2007-08

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1) INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1388/DEL/2023[2010-11]Status: DisposedITAT Delhi31 Aug 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1) , INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1385/DEL/2023[2006-07]Status: DisposedITAT Delhi31 Aug 2023AY 2006-07

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1), INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1387/DEL/2023[2009-10]Status: DisposedITAT Delhi31 Aug 2023AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, CIRCLE-3(1)(1) INT. TAXATION, NEW DELHI vs. RAYTHEON COMPANY, UNITED STATES

In the result, all the appeals of the Revenue for the

ITA 1386/DEL/2023[2008-09]Status: DisposedITAT Delhi31 Aug 2023AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

u/s 271(1) (c) of the Act on account of ‘Concealment of Particulars of Income' which is being contested by the Appellant in this appeal. Accordingly, my findings with reference to the above has been laid down in the subsequent paragraphs. 5.2 The Appellant's case consists of the following issues on merits: 1. Existence of PE in India

DCIT, NEW DELHI vs. M/S. PODDAR PIGMENTS LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 2219/DEL/2014[2007-08]Status: DisposedITAT Delhi04 Oct 2016AY 2007-08

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2007-08 Vs. M/S. Poddar Pigments Ltd., A- Dcit, Circle-14(1), New Delhi 283, Ground Floor, Okhla Indl. Area-1, New Delhi. Pan : Aaacp1125E (Appellant) (Respondent) Appellant By Sh. F.R. Meena, Sr.Dr Respondent By Sh. P.C. Parwal, Fca Date Of Hearing 08.08.2016 Date Of Pronouncement 05.10.2016 Order Per O.P. Kant, A.M.: This Appeal By The Revenue Is Directed Against The Order Dated 15/01/2014 Passed By The Learned Commissioner Of Income-Tax (Appeals) For Assessment Year 2007-08, Wherein He Allowed The Appeal Of The Assessee Against Order Of The Assessing Officer Dated 29/03/2012 Levying Penalty Under Section 271(1)(C) Of The Income-Tax Act, 1961. The Grounds Of Appeal Raised By The Revenue Are As Under: I. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Erred In Deleting The Penalty Made By The Assessing Officer U/S 271(1)(C) Of The Act On Account Of Additions Under The Head Of U/S 40(A)(I) Amounting To Rs.9,14,191/- & Ltcg Amounting To Rs.41,62,154/- Holding That The Assessee Has Not Furnished Any Inaccurate Particulars Or Has Made Any Deliberate Attempt To Conceal Income. Ii. On The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Erred In Deleting The Above

Section 143(3)Section 271(1)(c)Section 40

271(l)(c) for not deducting and depositing TDS on time, held that where there was no concealment of income or furnishing of inaccurate particulars of income by assessee, nonpayment of TDS being a technical default; deletion of penalty was justified. In view of above, penalty levied u/s

ACIT, NEW DELHI vs. M/S DEEPALI DESIGN & EXHIBITS, NEW DELHI

In the result, the Appeal filed by the Revenue stands dismissed

ITA 6203/DEL/2016[2011-12]Status: DisposedITAT Delhi07 Dec 2018AY 2011-12

Bench: Shri H.S. Sidhu & Shri O.P. Kantassessment Year: 2011-12 Acit, Central Circle-17 Vs. M/S Deepali Designs & Exhibits 9, 1St Floor, Behind Punjab Room No. 103, First Floor, Hall No. 1, Kesri, Wazirpur Industrial Ara Centre, Area, New Delhi – 110 035 E-2, Jhandewalan, (Pan: Aaffd1639M) New Delhi – 110 057 (Appellant) (Respondent) Department By : Sh. B.S. Rajpurohit, Sr. Dr. Assessee By : Sh. Ridhi Karan Agarwal, Ca

For Appellant: Sh. Ridhi Karan Agarwal, CAFor Respondent: Sh. B.S. Rajpurohit, Sr. DR
Section 153ASection 271(1)Section 271(1)(c)Section 274Section 40A(3)

TDS and amounts u/s. 40A(3) of the Act. Although Ld. CIT(A) restricted the addition of Rs. 77,775/- out of Rs. 1,55,550/- made by the AO on account of disallowance of 1/5th of expenditure. On the issues of addition of Rs. 20,59,385/- on account of disallowance of unaccounted income and addition

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

ITA 618/DEL/2022[2013-14]Status: DisposedITAT Delhi26 Jul 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

271 D/271E even when the loans and their repayment had not been accounted for in the books of the assessee. It was submitted that in the present case it is evident from the statement of Sh. Devidas Tikamdas Chattani that the requisitioned material represented the duplicate set of books of accounts, i.e. ‘unaccounted & unrecorded books of account’ at third party

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

ITA 611/DEL/2022[2010-11]Status: DisposedITAT Delhi26 Jul 2024AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

271 D/271E even when the loans and their repayment had not been accounted for in the books of the assessee. It was submitted that in the present case it is evident from the statement of Sh. Devidas Tikamdas Chattani that the requisitioned material represented the duplicate set of books of accounts, i.e. ‘unaccounted & unrecorded books of account’ at third party

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

ITA 614/DEL/2022[2013-14]Status: DisposedITAT Delhi26 Jul 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

271 D/271E even when the loans and their repayment had not been accounted for in the books of the assessee. It was submitted that in the present case it is evident from the statement of Sh. Devidas Tikamdas Chattani that the requisitioned material represented the duplicate set of books of accounts, i.e. ‘unaccounted & unrecorded books of account’ at third party

VISHWANATH AGGARWAL,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

ITA 615/DEL/2022[2010-11]Status: DisposedITAT Delhi26 Jul 2024AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

271 D/271E even when the loans and their repayment had not been accounted for in the books of the assessee. It was submitted that in the present case it is evident from the statement of Sh. Devidas Tikamdas Chattani that the requisitioned material represented the duplicate set of books of accounts, i.e. ‘unaccounted & unrecorded books of account’ at third party

VISHWANATH AGGARWAL ,DELHI vs. THE ADDL. CIT, CENTRAL RANGE-05, DELHI

The appeals of the assessee are allowed and the penalty is deleted

ITA 616/DEL/2022[2011-12]Status: DisposedITAT Delhi26 Jul 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

271 D/271E even when the loans and their repayment had not been accounted for in the books of the assessee. It was submitted that in the present case it is evident from the statement of Sh. Devidas Tikamdas Chattani that the requisitioned material represented the duplicate set of books of accounts, i.e. ‘unaccounted & unrecorded books of account’ at third party