VIJAY CHOUDHARY,MUMBAI vs. ACIT 1(2), INDORE

Appeals are allowed

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

deemed dividend’ u/s 2(22)(e) and it is a settled law that the penalty u/s 271(1)(c) cannot

VIJAY CHOUDHARY,ANDHERI MUMBAI vs. ACIT 1(2), INDORE

Appeals are allowed

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

deemed dividend’ u/s 2(22)(e) and it is a settled law that the penalty u/s 271(1)(c) cannot

VIJAY CHOUDHARY,MUMBAI vs. ACIT 1(2), INDORE

Appeals are allowed

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

deemed dividend’ u/s 2(22)(e) and it is a settled law that the penalty u/s 271(1)(c) cannot

RADHESHYAM AGARWAL,BHOPAL vs. THE PCIT, CENTRAL, BHOPAL , BHOPAL

u/s India pharmaceuticals\nreported in [1980]123ITR 874[MP] & laid emphasis on\nfollowing:-\n\"It was contended by learned counsel appearing for the revenue that\nproceedings for assessment under s. 143 of the Act are proceedings\nwhere the ITO had to apply his mind to the circumstances which would\nattract the provisions contained in s. 271

HARPREET KAUR,BHOPAL vs. INCOME-TAX OFFICER, 5(2), BHOPAL, BHOPAL

Appeal is allowed in terms mentioned above

271(1)(c) of the 'Act' are\ninitiated separately. After rejection of claim LTCG as claimed by the assessee\nis being computed separately in forthcoming paras of the body of the\nassessment order.\nAddition - Rs.8,61,000/-.\n3. Computation of LTCG:\nDescription\nAmount\nComputation\nFull\nvalue of Consideration\n(sale\nRs.410000/-\nconsideration received in lieu of sale of land\nlocated

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

271(1)(c) without considering the fact that transfer pricing adjustment has been made on account of difference of opinion, interpretation of provisions of law, etc. and not due to any concealment of or furnishing of inaccurate particulars of income by the Appellant.” 2. The assessee has also filed additional grounds of appeal vide application dated 14th August