DR. VINOD BHANDARI,INDORE vs. THE ACIT CIR. 2(1), INDORE

In the result appeal of the assessee is allowed

Bench: Shri Kul Bharat & Shri Manish Boradassessment Year: 2012-13 Shri Vinod Bhandari, Pr. Cit(1), Indore 21- Gf, Bhandari House, Talkies, Scheme No.54, Vs. Vijay Nagar, Indore (Appellant) (Revenue ) Pan No.Abnpb6240M Assessment Year: 2012-13

revised return. Therefore it cannot also be said that there was anything prejudicial to the interest of the Revenue. Further mere non initiation of penalty u/s 271(1)(c) cannot be considered a good ground for invoking section 263

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

revision\nproceedings u/s 263 of the Act. The act of non initiation of\npenalty proceeding\nu/s\n271AAC(1) triggered the\nproceedings u/s 263 of the Act as in the \"Impugned\nAssessment order\" there is not even a whisper about the\ninitiation of the penalty proceedings u/s 271AAC(1) nor there\nis any recording of satisfaction with regard

M/S. CHARITRA GOLD PVT. LTD.,RATLAM vs. THE PR. CIT, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

DHIRENDRA INTERNATIONAL (P) LTD.,NEEMUCH vs. PR. CIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI MANISH MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI ADITYA MUNDRA,DEWAS vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI GOVIND DAS MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

SHRI MANOJ MUNDRA,INDORE vs. PCIT UJJAIN, UJJAIN

In the result all the appeals of the assessee(s) (i) Shri Aditya

Bench: Hon’Ble Kul Bharat & Hon’Ble Manish Borad

revision was set-aside by the Tribunal because it was found that the assessee had furnished requisite information and the income tax officer had completed 41 Aditya Mundra &Others ITA No.632, 634,635 & 637, 517 & 750/Ind/2019 the assessment after considering all facts. Held, that the Tribunal was justified in Law reversing the order of the Commissioner u/s. 263

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

revision-order passed by PCIT u/s 263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271

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

revision-order passed by PCIT u/s 263, the AO re-framed assessment wherein he disallowed assessee’s claim, (iii) the AO thereafter imposed penalty u/s 271

AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL

In the result, appeal of assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023

penalty under Section 271 (1) (c) of IT Act which operates in a different realm and Malabar Industrial Co. Ltd., does not rescue the Revenue as impugned notice is hit by the vice of lack of jurisdiction on account of being time barred. 3(xxii) One other reason given by the learned single Judge for dismissing the Assessee's writ

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

Appeal is allowed

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

263 or section 264, after the expiry of six months from the end of the month in which such order of revision is passed; (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty Page 10 of 33 Shri Vimal Todi

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

Appeals are allowed

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

263 or section 264, after the expiry of six months from the end of the month in which such order of revision is passed; (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from

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

Appeals are allowed

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

263 or section 264, after the expiry of six months from the end of the month in which such order of revision is passed; (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from

SHYAM PRATAP SINGH SHEKHAWAT,LUDHIANA vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2, BHOPAL

In the result appeal of the assessee is dismissed

Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2010-11 Shri Shyam Pratap Singh Shekhawat Vs Pr. Cit, Zonal Office, Bhai Bala Chowk, Bhopal 5Th Floor, Noble Enclave, Ludhiana (Appellant) (Respondent) Pan Acaps0740F Revenue By Smt. Ashima Gupta, Cit Assessee By S/Shri Ashish Goyal & N.D. Patwa, Advocates Date Of Hearing 22.05.2019 Date Of Pronouncement 26.07.2019 O R D E R

revised return of income at 4 Shyam Pratap Singh Shekhawat Rs.10,22,892/-. Additions were made by Ld. A.O but he failed to initiate penalty proceedings u/s 271(1)(c) of the Act. Subsequently Ld. PCIT exercising power u/s 263

SHRI UMAKANT SHARMA,JHABUA vs. THE JCIT , RATLAM

In the result, appeal for A

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

263 or assessment order or other orders are subject matter of appeal before the Hon’ble High Court or Hon’ble Supreme Court. Thus, it is clear that section 275, pre supposes the existence of assessment proceedings/revision proceedings or appeal proceedings arising from the assessment order or revision order and the limitation is provided as per outcome of these proceedings

SHRI UMAKANT SHARMA,JHABUA vs. THE JCIT , RATLAM

In the result, appeal for A

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

263 or assessment order or other orders are subject matter of appeal before the Hon’ble High Court or Hon’ble Supreme Court. Thus, it is clear that section 275, pre supposes the existence of assessment proceedings/revision proceedings or appeal proceedings arising from the assessment order or revision order and the limitation is provided as per outcome of these proceedings

SHRI UMAKANT SHARMA,JHABUA vs. THE JCIT , RATLAM

In the result, appeal for A

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

263 or assessment order or other orders are subject matter of appeal before the Hon’ble High Court or Hon’ble Supreme Court. Thus, it is clear that section 275, pre supposes the existence of assessment proceedings/revision proceedings or appeal proceedings arising from the assessment order or revision order and the limitation is provided as per outcome of these proceedings