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723 results for “penalty u/s 271”+ Unexplained Cash Creditclear

Sorted by relevance

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Key Topics

Section 68110Addition to Income87Section 271(1)(c)73Penalty56Section 153A45Section 143(3)36Section 153C27Section 14826Section 143(2)

THAPAR HOMES LIMITED,NEW DELHI vs. ACIT, CENTRAL CIRCLE-15, NEW DELHI

ITA 1054/DEL/2020[2009-10]Status: DisposedITAT Delhi19 Aug 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 570, 571 & 41 /िद"ी/2017 (िन.व. 2006-07, 2007-08 & 2009-10)

For Appellant: S/Shri Vikas Jain, Hardik Jayal, Nilesh Singh &For Respondent: Shri Mahesh Kumar, CIT(DR)
Section 153ASection 68Section 69C

unexplained cash credit u/s 68. Therefore, the same is added to the assessee's income. As the assessee has concealed income penalty u/s 271

ACIT, NEW DELHI vs. M/S. THAPAR HOMER LTD., NEW DELHI

ITA 548/DEL/2017[2009-10]Status: DisposedITAT Delhi

Showing 1–20 of 723 · Page 1 of 37

...
25
Section 14723
Unexplained Cash Credit21
Search & Seizure20
19 Aug 2025
AY 2009-10

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 570, 571 & 41 /िद"ी/2017 (िन.व. 2006-07, 2007-08 & 2009-10)

For Appellant: S/Shri Vikas Jain, Hardik Jayal, Nilesh Singh &For Respondent: Shri Mahesh Kumar, CIT(DR)
Section 153ASection 68Section 69C

unexplained cash credit u/s 68. Therefore, the same is added to the assessee's income. As the assessee has concealed income penalty u/s 271

ACIT, NEW DELHI vs. M/S. THAPAR HOMES LTD., NEW DELHI

ITA 1142/DEL/2017[2006-07]Status: DisposedITAT Delhi19 Aug 2025AY 2006-07

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 570, 571 & 41 /िद"ी/2017 (िन.व. 2006-07, 2007-08 & 2009-10)

For Appellant: S/Shri Vikas Jain, Hardik Jayal, Nilesh Singh &For Respondent: Shri Mahesh Kumar, CIT(DR)
Section 153ASection 68Section 69C

unexplained cash credit u/s 68. Therefore, the same is added to the assessee's income. As the assessee has concealed income penalty u/s 271

THAPAR HOMES LTD.,NEW DELHI vs. ACIT, NEW DELHI

ITA 570/DEL/2017[2006-07]Status: DisposedITAT Delhi19 Aug 2025AY 2006-07

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 570, 571 & 41 /िद"ी/2017 (िन.व. 2006-07, 2007-08 & 2009-10)

For Appellant: S/Shri Vikas Jain, Hardik Jayal, Nilesh Singh &For Respondent: Shri Mahesh Kumar, CIT(DR)
Section 153ASection 68Section 69C

unexplained cash credit u/s 68. Therefore, the same is added to the assessee's income. As the assessee has concealed income penalty u/s 271

THAPAR HOMES LTD.,NEW DELHI vs. ACIT, NEW DELHI

ITA 571/DEL/2017[2007-08]Status: DisposedITAT Delhi19 Aug 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 570, 571 & 41 /िद"ी/2017 (िन.व. 2006-07, 2007-08 & 2009-10)

For Appellant: S/Shri Vikas Jain, Hardik Jayal, Nilesh Singh &For Respondent: Shri Mahesh Kumar, CIT(DR)
Section 153ASection 68Section 69C

unexplained cash credit u/s 68. Therefore, the same is added to the assessee's income. As the assessee has concealed income penalty u/s 271

HITESH CONSTRUCTION P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCAL-06, NEW DELHI

ITA 5105/DEL/2017[2008-09]Status: DisposedITAT Delhi25 Aug 2021AY 2008-09

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Ms. Anima Burnwal, Senior DR
Section 143Section 153ASection 271Section 271(1)(c)Section 274

unexplained cash credits And at an income of Rs1,00,000/- each for AYs 2010-11, 2011-12 & 2011-12 respectively by making addition of Rs.1,00,000/- on account of disclosure made by the assessee before the Income Tax Settlement Commission. Penalty proceedings have been initiated against the assessee u/s 271

HITESH CONSTRUCTION P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCAL-06, NEW DELHI

ITA 5107/DEL/2017[2010-11]Status: DisposedITAT Delhi25 Aug 2021AY 2010-11

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Ms. Anima Burnwal, Senior DR
Section 143Section 153ASection 271Section 271(1)(c)Section 274

unexplained cash credits And at an income of Rs1,00,000/- each for AYs 2010-11, 2011-12 & 2011-12 respectively by making addition of Rs.1,00,000/- on account of disclosure made by the assessee before the Income Tax Settlement Commission. Penalty proceedings have been initiated against the assessee u/s 271

HITESH CONSTRUCTION P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCAL-06, NEW DELHI

ITA 5106/DEL/2017[2009-10]Status: DisposedITAT Delhi25 Aug 2021AY 2009-10

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Ms. Anima Burnwal, Senior DR
Section 143Section 153ASection 271Section 271(1)(c)Section 274

unexplained cash credits And at an income of Rs1,00,000/- each for AYs 2010-11, 2011-12 & 2011-12 respectively by making addition of Rs.1,00,000/- on account of disclosure made by the assessee before the Income Tax Settlement Commission. Penalty proceedings have been initiated against the assessee u/s 271

HITESH CONSTRUCTION P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCAL-06, NEW DELHI

ITA 5108/DEL/2017[2011-12]Status: DisposedITAT Delhi25 Aug 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Ms. Anima Burnwal, Senior DR
Section 143Section 153ASection 271Section 271(1)(c)Section 274

unexplained cash credits And at an income of Rs1,00,000/- each for AYs 2010-11, 2011-12 & 2011-12 respectively by making addition of Rs.1,00,000/- on account of disclosure made by the assessee before the Income Tax Settlement Commission. Penalty proceedings have been initiated against the assessee u/s 271

HITESH CONSTRUCTION P.LTD,NEW DELHI vs. ACIT, CENTRAL CIRCAL-06, NEW DELHI

ITA 5109/DEL/2017[2012-13]Status: DisposedITAT Delhi25 Aug 2021AY 2012-13

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh(Through Video Conference)

For Appellant: Shri P.C. Yadav, AdvocateFor Respondent: Ms. Anima Burnwal, Senior DR
Section 143Section 153ASection 271Section 271(1)(c)Section 274

unexplained cash credits And at an income of Rs1,00,000/- each for AYs 2010-11, 2011-12 & 2011-12 respectively by making addition of Rs.1,00,000/- on account of disclosure made by the assessee before the Income Tax Settlement Commission. Penalty proceedings have been initiated against the assessee u/s 271

RADHIKA SURGICAL PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 6, NEW DELHI

In the result, appeal of the assessee is allowed

ITA 5089/DEL/2017[2009-10]Status: DisposedITAT Delhi31 May 2021AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing) Radhika Surgical Pvt. Ltd. Vs. Acit C-30, Panchsheel Enclave, Central Circle – 6, New Delhi-110017 New Delhi Pan : Aadcr 5053 L (Appellant) (Respondent) Assessee By Shri P. C. Yadav, Adv. Revenue By Shri Farhad Khan, Sr. D.R. Date Of Hearing: 05/04/2021 Date Of Pronouncement: 31/05/2021 Order Per Anil Chaturvedi, Am :

Section 132Section 153CSection 245CSection 271Section 271(1)(c)Section 274

unexplained cash credits After giving effect to the order of CIT(A), the Assessing Officer after providing the assessee an opportunity to show cause as to why 8 penalty u/s 271

M/S SINGHAL STRIPS LTD.,,DELHI vs. DCIT,, NEW DELHI

ITA 2325/DEL/2017[2000-01]Status: DisposedITAT Delhi17 Dec 2019AY 2000-01

Bench: Shri R.K.Panda & Shri Kuldip Singh

For Appellant: NoneFor Respondent: Shri S.S.Rana, CIT(DR)
Section 147Section 271Section 271(1)(c)Section 274Section 68

cash credit and unexplained 3 ITA No. 2325/Del./2017 expenditure respectively, AO proceeded to initiate the penalty proceedings against the assessee u/s 271

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

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

ITA 612/DEL/2022[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

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

ITA 617/DEL/2022[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling

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

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

ITA 613/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

credit side is having the sums of amounts repaid in cash by the assessee during the year under consideration. Referring to the assessment order it was submitted that allegedly the assessee had received cash loans from the Ashram to the tune of Rs. 21,79,65,316/- and made repayments in cash totaling