S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

ACIT-5(1), INDORE vs. S T I INDIA LTD., INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

S T I INDIA LTD.,INDORE vs. ACIT-5(1), INDORE

Appeals are disposed of as under:

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condoned and appeal is proceeded for hearing. 4. The grounds raised by parties are as under: Assessee’s ITA No. 11/Ind/2019 for AY 2012-13: Page 2 of 29 STI India Ltd. ITA Nos.11, 850, 12, 13/Ind/2019 & 22, 784, 23 & 24/Ind/2019 (A.Y.2012-13 to 2015-16) 1. That the Ld. CIT(A) erred in maintaining disallowance

PRASAM RAKESH CHOUDHARY,GIRNAR SOCIETY, BAPURAO GALLI, ITWARI, NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, BHOPAL , BHOPAL

Appeal is dismissed

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

b) Without prejudice to the above, the Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) decisively rejected the quasi-criminal characterization of penalty under Section Page 2 of 17 M/s. Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHOPOAL, BHOPAL vs. M/S RASHTRIYA TAKNIKI SHIKSHAK PRASHIKSHAN EVAM ANUNSANDHAN SANSTHAN, BHOPAL

Appeal is dismissed

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

b) Without prejudice to the above, the Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) decisively rejected the quasi-criminal characterization of penalty under Section Page 2 of 17 M/s. Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271

C.I. FINLEASE PRIVATE LIMITED,BHOPAL vs. DCIT-1(1), BHOPAL

Appeal is dismissed

b)\nAjay Dabre Vs. Pyare Ram 2023 SCC Online SC 92:\n'13. This Court in the case of Basawaraj v. Special Land Acquisition\nOfficer while rejecting an application for condonation of delay for lack of\nsufficient cause has concluded in Paragraph 15 as follows:\n\"15. The law on the issue can be summarised to the effect that\nwhere

VIMAL TODI,INDORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, INDORE

Appeals are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condone delay, admit appeal and proceed with hearing. 3.Since the issue for adjudication in these appeals is identical; they were heard together at the request of parties and are being disposed of by this consolidated order for the sake of convenience, brevity and clarity. 4. The background facts leading to these appeals are such that the asesesee was a director

VIMAL TODI,INDORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, INDORE

Appeals are allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

condone delay, admit appeal and proceed with hearing. 3.Since the issue for adjudication in these appeals is identical; they were heard together at the request of parties and are being disposed of by this consolidated order for the sake of convenience, brevity and clarity. 4. The background facts leading to these appeals are such that the asesesee was a director

GANPAT SINGH,PIPLANI vs. ITO 3(1) BHOPAL, BHOPAL

Appeal is partly allowed

delay in filing the appeal, taking a liberal view due to the assessee's condition and the merit of the appeal. It held that the non-compliance with multiple notices seeking the same information constitutes a single default.", "result": "Partly Allowed", "sections": [ "271(1)(b)", "142(1)", "253(5)", "273B" ], "issues": "Whether to condone

KUSUM GEORGE JACOB,BHOPAL vs. ITO - 2(1) BHOPAL, AAYKAR BHAWAN, HOSHANGABAD

Appeal is allowed for statistical purpose

condoned the delay. The Tribunal also noted that certain documents were presented by the assessee's representative, which were not filed before the AO or examined by the CIT(A).", "result": "Allowed for statistical purpose", "sections": [ "147", "144", "250", "253", "271(1)(c)", "271F", "271(1)(b

SURESH PATEL,DEWAS vs. CIT(A) ,NFAC, DELHI

Appeal is dismissed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

271(1)(c) [i.e. penalty qua the addition made in assessment-order] that the assessee consulted his counsel and became aware of the impugned order having been passed by CIT(A). Immediately thereafter, according to the consultation given by counsel, the appeal fee was paid on 24.01.2025 and present appeal was filed without further delay. Ld. AR very humbly submitted

SURESH PATEL,DEWAS vs. CIT(A),NFAC, DELHI

Appeal is dismissed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

271(1)(c) [i.e. penalty qua the addition made in assessment-order] that the assessee consulted his counsel and became aware of the impugned order having been passed by CIT(A). Immediately thereafter, according to the consultation given by counsel, the appeal fee was paid on 24.01.2025 and present appeal was filed without further delay. Ld. AR very humbly submitted

M/S C.I. BUILDERS PVT. LTD.,BHOPAL vs. THE ACIT, 1(2), BHOPAL

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

271(1)(c) and consulted with a different counsel for filing of appeals in penalty matters that the assessee came to know that the counsel had not filed appeals against impugned orders. Immediately thereafter, the assessee Page 6 of 16 C.I. Builders Private Limited, Bhopal ITA Nos. 247 & 248/Ind/2023 A.Y.2010-11 & 2012-13 arranged to file these appeals on 03.07.2023 alongwith

M/S C.I. BUILDERS PVT. LTD.,BHOPAL vs. THE DCIT 1(1), BHOPAL

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

271(1)(c) and consulted with a different counsel for filing of appeals in penalty matters that the assessee came to know that the counsel had not filed appeals against impugned orders. Immediately thereafter, the assessee Page 6 of 16 C.I. Builders Private Limited, Bhopal ITA Nos. 247 & 248/Ind/2023 A.Y.2010-11 & 2012-13 arranged to file these appeals on 03.07.2023 alongwith

INCOME TAX OFFICER 5(1), INDORE vs. UMANG DEVELOPERS, INDORE

Appeals are dismissed

271.\"\nAdditional evidences are normally not allowed so as to bring finality to\nassessment proceedings. However, this cannot be at the cost of natural\njustice. Therefore, Rule 46A(1)(b) & 46A(1)(c) give opportunity to appellant to\nproduce additional evidences in cases where an appellant is prevented by\nsufficient cause from producing such evidences. The rule is ended