PRAMOD KUMAR GUPTA,BHOPAL vs. DCIT CIRCLE 5 (1)- BHOPAL, BHOPAL

In the result appeal of the assessee is allowed, penalty is\ndeleted

u/s 271(1)(C) they intend imposing the penalty on the\nassessee. In the absence of any averment on “concealment of\nincome by assessee” or furnishing inaccurate particular of\nincome” the notice(s) (supra) are defective, illegal & bad in law.\n4.5 We hold that penalty is in addition to tax liability of the\nassessee. It entails serious civil consequences

PREM CHAWLA LEGAL HEIR OF LATE SMT. SUDESH CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for sake of brevity). The assessee is aggrieved by the order bearing Number CIT(A)-3 Bhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s 250 of the Act, which is hereinafter referred to as the “impugned order”. The relevant Assessment Year is 2000-2001 and the Page

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA LEGAL HEIR OF LATE SMT SUDESH CHAWLA,BHOPAL vs. ASSTT. COMM. OF I.TAX 1(1) BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Ncolony,\Nbhopal\N(Assessee/Appellant)\Nacit-1(1),\Nbhopal\Nबनाम /\Nvs.\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing 19.03.2025\Ndate Of Pronouncement 07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA LEGAL HEIR OF LATE SMT. SUDESH CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\N\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Ncolony,\Nbhopal\N(Assessee/Appellant)\Nacit-1(1),\Nbhopal\Nबनाम /\Nvs.\N(Revenue/Respondent)\N\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing 19.03.2025\Ndate Of Pronouncement 07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\N\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Nacit-1(1),\Ng-2/161, Gulmohar\Nbhopal\Ncolony,\Nbhopal\Nबनाम /\Nvs.\N(Assessee/Appellant)\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing\N19.03.2025\Ndate Of Pronouncement\N07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Ncolony,\Nbhopal\N(Assessee/Appellant)\Nacit-1(1),\Nbhopal\Nबनाम /\Nvs.\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing\N19.03.2025\Ndate Of Pronouncement\N07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA LEGAL HEIR OF LATE SMT. SUDESH CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for sake of brevity). The assessee is aggrieved by the order bearing Number CIT(A)-3 Bhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s 250 of the Act, which is hereinafter referred to as the “impugned order”. The relevant Assessment Year is 2000-2001 and the Page

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA LEGAL HEIR OF LATE SMT. SUDESH CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for sake of brevity). The assessee is aggrieved by the order bearing Number CIT(A)-3 Bhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s 250 of the Act, which is hereinafter referred to as the “impugned order”. The relevant Assessment Year is 2000-2001 and the Page

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’ for sake of brevity). The assessee is aggrieved by the order bearing Number CIT(A)-3 Bhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s 250 of the Act, which is hereinafter referred to as the “impugned order”. The relevant Assessment Year is 2000-2001 and the Page

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Ncolony,\Nbhopal\N(Assessee/Appellant)\Nacit-1(1),\Nbhopal\Nबनाम /\Nvs.\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing\N19.03.2025\Ndate Of Pronouncement\N07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA LEGAL HEIR OF LATE SMT. SUDESH CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Nacit-1(1),\Ncolony,\Nbhopal\Nbhopal\Nबनाम /\Nvs.\N(Assessee/Appellant)\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing\N19.03.2025\Ndate Of Pronouncement\N07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

PREM CHAWLA,BHOPAL vs. ASSISTANT COMMISSIONER OF INCOME TAX-1(1), BHOPAL, BHOPAL

Appeals of the assessee are allowed mutatis mutandis

Bench: Shri Bhagirath Mal Biyani, Accountant\Nmember\Nand\Nshri Paresh M Joshimember\Nita Nos.673 To 679/Ind/2024\N Assessment Years: 2000-2001 To 2006-2007\Nprem Chawla,\Ng-2/161, Gulmohar\Ncolony,\Nbhopal\N(Assessee/Appellant)\Nacit-1(1),\Nbhopal\Nबनाम /\Nvs.\N(Revenue/Respondent)\Npan: Aaopc3494N\Nassessee By Shri S.S. Deshpande, Ar\Nrevenue By Shri Ashish Porwal, Sr. Dr\Ndate Of Hearing\N19.03.2025\Ndate Of Pronouncement\N07.

Section 253 of the Income Tax Act, 1961 (hereinafter\nreferred to as the 'Act' for sake of brevity). The assessee is\naggrieved by the order bearing Number CIT(A)-3\nBhopal/IT/10289/2016-17/139 dated 28.06.2024 of CIT(A) u/s\n250 of the Act, which is hereinafter referred to as the “impugned\norder\". The relevant Assessment Year is 2000-2001 and the\ncorresponding

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

Appeals are allowed

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

253. The limitation for the cases falling under this category, is two years from the end of the financial year in which the proceedings, in the course of which the action for imposition of penalty has been initiated, were completed; or six months from the end of the month in which the order of the appellate authority was received

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

Appeals are allowed

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

253. The limitation for the cases falling under this category, is two years from the end of the financial year in which the proceedings, in the course of which the action for imposition of penalty has been initiated, were completed; or six months from the end of the month in which the order of the appellate authority was received

JAYGANGA EXIM INDIA PRIVATE LIMITED ,INDORE vs. ACIT CENTRAL-2 , BHOPAL

The appeals of the assessee are allowed

Bench: DR. MANISH BORAD, ACCOUNTANT MEMBER\nAND\nSHRI PARESH M JOSHI (Judicial Member)

Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the “Act” for sake of brevity) before this Tribunal. The assessee is aggrieved by orders in first appeal Number: CIT(A)-3, Bhopal/IT/10843/2014-16 & CIT(A)-3, Bhopal/IT/12504/2017-18 both dated 29.01.2025 passed by Ld. CIT(A), passed U/s 250 of the Act which is hereinafter referred

RVR TECHNOLOGIES LTD.,MANDIDEEP vs. ITO-2(1), BHOPAL

In the result, appeal for A

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

253 or an appeal to the High Court under section 260A or an appeal to the Supreme Court under section 261 or revision under section 263 or section 264 and an order imposing or enhancing or reducing or cancelling penalty or dropping the proceedings for the imposition of penalty is passed before the order of the Commissioner (Appeals