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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

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

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

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:-

reassessments conducted pursuant to Section 153A.Therefore, even if no additions are made to the income of the Assessee under Section 153A, it does not absolve them from liability under Sections 27ID and 271E if they are found to have contravened the provisions of Sections 269SS and 269T. As such, the penalties prescribed under Sections 27ID and 27IE serve a distinct

JAGJIT SINGH,PANIPAT vs. PR.CIT, KARNAL

In the result, appeal of Assessee allowed

Bench: Shri Bhavnesh Saini & Shri Prashant Maharishi

reassessment proceedings under section 148/143(3) accepting the return of income of the assessee. The Ld. Pr. CIT on perusal of the assessment 3 ITA.No.2777/Del./2018 Shri Jagjit Singh, Panipat. record and relevant material on record found certain apparent discrepancies and errors. Accordingly, show cause notice under section 263 of the Income-Tax Act was issued to the assessee

DCIT CENTRAL CIRCLE 1 DELHI, DELHI vs. SAHARA INDIA FINANCIAL CORPORATION LTD, LUCKNOW

In the result, appeal of the Revenue is dismissed

reassessment proceedings under Section 153C of the Act.”\n3.6 The above discussion on the legal issues surrounding the admission\nof a ground under Rule 27 reveals as under: -\ni. The assessee can support a favourable order of CIT(A) by tendering\na ground which was raised before the CIT(A) but was either held\nagainst him or not adjudicated

M/S. SARVOTTAM CONSTRUCTIONS PVT. LTD,NEW DELHI vs. ACIT, NEW DELHI

In the result, appeal of the assessee is allowed

Bench: Shri G.D. Agrawal, Hon’Ble & Shri K. Narasimha Chary

reassessment proceedings under section 147 of the Act. However during such proceedings Smt. Kavitha Aggarwal gave a go bye to her earlier statement and stated that as a matter of fact she paid the advance amount of Rs. 25 lakhs to the assessee and further stated that whatever she had stated on earlier occasion was incorrect. Ld. AO, therefore, passed

ITO, NEW DELHI vs. M/S VISHU IMPEX PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue are dismissed and the

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

271D & 271E of the Act are barred by limitation and since this issue is taken up for the first time before the ITAT in the nature of additional ground, therefore, the same may kindly be admitted for adjudication. The ld. AR placed reliance on the proposition laid down by the Hon'ble Supreme Court in the case of National Thermal

ITO, NEW DELHI vs. M/S VISHU IMPEX PVT. LTD., NEW DELHI

In the result, both the appeals of the Revenue are dismissed and the

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

271D & 271E of the Act are barred by limitation and since this issue is taken up for the first time before the ITAT in the nature of additional ground, therefore, the same may kindly be admitted for adjudication. The ld. AR placed reliance on the proposition laid down by the Hon'ble Supreme Court in the case of National Thermal

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings

PR. COMMISSIONER OF INCOME TAX-06 vs. NIKKI DRUGS & CHEMICALS PVT. LTD

271D of the Act on account of sums received by the Assessee in cash from various persons. 13. The Assessee as well as the Revenue preferred appeals against the orders passed by the CIT(A). Whilst the Assessee was mainly aggrieved by the decision of the CIT(A) in rejecting its contention that the proceedings