SANJAY KUMAR AGRAWAL,BURHANPUR vs. JOINT COMMISSIONER OF INCOME TAX (OSD) CENTRAL-1, INDORE

u/s Section 274 read\nwith Section 271(1)(c) followed by follow-up letters dated 31.05.2018. Copies\nof show-cause notices and follow-up letters are placed in Paper-Book at\nPages 141-142, 155-156 & 157-158. Ultimately, the AO imposed penalty\nu/s Section 271(1)(c) of Rs.2,10,000/-, 2,70

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

271(1)(c) and on appeal, the Hon’ble Supreme Court exonerated assessee from penalty. The relevant portion of Hon’ble Supreme Court’s order is re-produced below: “5. Even though the Statement indicated that the provision towards payment of gratuity was not allowable, the assessee claimed a deduction thereon in its return of income. On the basis

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

271(1)(c) and on appeal, the Hon’ble Supreme Court exonerated assessee from penalty. The relevant portion of Hon’ble Supreme Court’s order is re-produced below: “5. Even though the Statement indicated that the provision towards payment of gratuity was not allowable, the assessee claimed a deduction thereon in its return of income. On the basis

SEEMA JAIN,INDORE vs. ITO 1(1), INDORE

Appeal is allowed

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year: 2013-14 Seema Jain, Ito 1(1) 73-Ba, Scheme No.94, Indore Regency Adrise, Near बनाम/ Bombay Hospital, Vs. Vijay Nagar, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Adtpj4652K Assessee By Shri Anil Khandelwal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 16.07.2025 Date Of Pronouncement 17.07.2025

u/s 271(1)( c ) is not sustainable. The same is deleted.” (b) ITAT Mumbai – Assistant Commissioner of Income-tax Vs. M/s Sunland Metal Recycling, ITA No. 6454/Mum/2011 – order dated 10.12.2014: “5. Having considered the rival submissions as well as relevant material on record, we note that in the assessment proceedings, the Assessing Officer Page 7 of 11 Seema Jain

SANJAY KUMAR AGRAWAL,BURHANUPUR vs. JOINT COMMISIIONER OF INCOME TAX -OSD, CENTRAL-1, INDORE , INDORE

u/s 274 read\nwith section 271(1)(c) followed by follow-up letters dated 31.05.2018. Copies\nof show-cause notices and follow-up letters are placed in Paper-Book at\nPages 141-142, 155-156 & 157-158. Ultimately, the AO imposed penalty\nu/s 271(1)(c) of Rs.2,10,000/-, 2,70

SANJAY KUMAR AGRAWAL ,BURHANPUR vs. JOINT COMMISSIONER OF INCOME TAX -OSD, CENTRAL-1, INDORE , INDORE

u/s 274 read\nwith section 271(1)(c) followed by follow-up letters dated 31.05.2018. Copies\nof show-cause notices and follow-up letters are placed in Paper-Book at\nPages 141-142, 155-156 & 157-158. Ultimately, the AO imposed penalty\nu/s 271(1)(c) of Rs.2,10,000/-, 2,70

AMIT ASHOK AGRAWAL,INDORE vs. ITO-2(2), INDORE

In the result, the quantum appeal of assessee is partly allowed for statistical purposes and penalty appeal of assesse is allowed

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

Penalty proceedings u/s 271(1)(c) are initiated for concealment of income.” 5.1. Thus, the AO made the addition on account of cash deposit of Rs.10,33,000/- in the saving bank account with CITI Bank, Indore. Before the CIT(A) the assesse claimed that the deposit made in the bank account was from the source of withdrawal from other

AMIT ASHOK AGRAWAL,INDORE vs. ITO-2(2), INDORE

In the result, the quantum appeal of assessee is partly allowed for statistical purposes and penalty appeal of assesse is allowed

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

Penalty proceedings u/s 271(1)(c) are initiated for concealment of income.” 5.1. Thus, the AO made the addition on account of cash deposit of Rs.10,33,000/- in the saving bank account with CITI Bank, Indore. Before the CIT(A) the assesse claimed that the deposit made in the bank account was from the source of withdrawal from other

IKON OVERSEAS PRIVATE LIMITED,BHOPAL vs. ITO 2(5), BHOPAL

In the result, both appeals of the assessee are allowed for statistical purposes

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

u/s 144 and penalty order under section 271(1)(c) for A.Y.2013-14. ITANo.53 & 54/Ind/2024 Ikon Overseas Private Ltd. 2. There is a delay of 41 days in quantum appeal filed by the assessee. The assessee has explained the cause of delay in the application for condonation of delay which is supported by the affidavit of the Director of the assesse

IKON OVERSEAS PRIVATE LIMITED,BHOPAL vs. ITO 2(5), BHOPAL

In the result, both appeals of the assessee are allowed for statistical purposes

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

u/s 144 and penalty order under section 271(1)(c) for A.Y.2013-14. ITANo.53 & 54/Ind/2024 Ikon Overseas Private Ltd. 2. There is a delay of 41 days in quantum appeal filed by the assessee. The assessee has explained the cause of delay in the application for condonation of delay which is supported by the affidavit of the Director of the assesse

INDORE MANDAL DAK TAR KARAMCHARI SAHAKARI SANSTHA MY. INDORE,INDORE vs. THE ADDITIONAL CIT , INDORE

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

70,08,955/- on account of deduction claimed under section 80P under chapter VI-A of Income Tax Act 1961as is admissible deduction to a co-operative society. The addition therefore made by AO is totally wrongand without considering the facts of the case. (4)That the appellant craves to leave add alter or amend any of the ground

INDORE MANDAL DAK TAR KARAMCHARI SAHAKARI SANSTHA MY. INDORE,INDORE vs. THE ADDITIONAL CIT , INDORE

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

70,08,955/- on account of deduction claimed under section 80P under chapter VI-A of Income Tax Act 1961as is admissible deduction to a co-operative society. The addition therefore made by AO is totally wrongand without considering the facts of the case. (4)That the appellant craves to leave add alter or amend any of the ground

INDORE MANDAL DAK TAR KARAMCHARI SAHAKARI SANSTHA MY. INDORE,INDORE vs. THE ADDITIONAL CIT , INDORE

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

70,08,955/- on account of deduction claimed under section 80P under chapter VI-A of Income Tax Act 1961as is admissible deduction to a co-operative society. The addition therefore made by AO is totally wrongand without considering the facts of the case. (4)That the appellant craves to leave add alter or amend any of the ground

INDORE MANDAL DAK TAR KARAMCHARI SAHAKARI SANSTHA MY. INDORE,INDORE vs. THE ADDITIONAL CIT , INDORE

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

70,08,955/- on account of deduction claimed under section 80P under chapter VI-A of Income Tax Act 1961as is admissible deduction to a co-operative society. The addition therefore made by AO is totally wrongand without considering the facts of the case. (4)That the appellant craves to leave add alter or amend any of the ground

INDORE MANDAL DAK TAR KARAMCHARI SAHAKARI SANSTHA MY. INDORE,INDORE vs. THE ADDITIONAL CIT , INDORE

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

70,08,955/- on account of deduction claimed under section 80P under chapter VI-A of Income Tax Act 1961as is admissible deduction to a co-operative society. The addition therefore made by AO is totally wrongand without considering the facts of the case. (4)That the appellant craves to leave add alter or amend any of the ground

NAVIN KUMAR JAIN,INDORE vs. INCOME TAX OFFICER FACELESS ASSESSMENT CENTRE, INDORE

In the result, both appeals of the assessee are allowed

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

Penalty preceding u/s 271(1)(b) of IT Act, 1961 for non compliance of notice issued u/s 142(1) of IT act dated 03.02.2022 is being initiated.” 5.5 It is manifest from the assessment order that the same was passed by the AO without considering the reply filed by the assessee vide acknowledgment dated 28.02.2022 as well as without considering

NAVIN KUMAR JAIN,INDORE vs. ITO ACIT DYCIT FACELESS ASSESSMENT, INDORE

In the result, both appeals of the assessee are allowed

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

Penalty preceding u/s 271(1)(b) of IT Act, 1961 for non compliance of notice issued u/s 142(1) of IT act dated 03.02.2022 is being initiated.” 5.5 It is manifest from the assessment order that the same was passed by the AO without considering the reply filed by the assessee vide acknowledgment dated 28.02.2022 as well as without considering

DEVGAS PATIDAR,BHOPAL vs. ITO - 2(4), BHOPAL

Appeal is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Shri Devgas Patidar, Income-Tax Officer, S/O Late Shree Bakshiram, 2(4), 3560, Madan Market Road, Bhopal बनाम/ Misrod, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Crzpp6677E Assessee By Shri Ashish Goyal & Shri N. D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.07.2024 Date Of Pronouncement 26.07.2024

penalty-order dated 18.09.2015 passed by learned ITO-2(4), Bhopal [“AO”] u/s 271(1)(c) of Income- tax Act, 1961 [“the Act”] for assessment-year [“AY”] 2007-08, the assessee has filed this appeal on the grounds mentioned in Form No. 36. Shri Devgas Patidar, Bhopal Assessment Year 2007-08 2. Heard the learned Representatives of both sides

SAIPHIA TECHNOLOGY PRIVATE LIMITED,BHOPAL vs. COMMISSIONER OF INCOME-TAX (APPEALS) , NATIONAL FACELESS APPEAL CENTRE (NFAC) DELHI

Appeal is partly allowed

Bench: Shri B.M. Biyani & Shri Udayan Das Guptaassessment Year:2015-16 Saiphia Technology Private Nfac Limited, Delhi 1St Floor Ankit Plaza, बनाम/ Kolar Road, Vs. Near Nayapura Bus Stop, Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aancs1814Q Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 20.01.2025 Date Of Pronouncement 22.01.2025

271(1)(c) imposing a penalty of Rs. 12,00,000/-. Aggrieved by penalty-order, the assessee filed first-appeal before CIT(A) but did not get any success. Now, the assessee has come in next appeal before us. Page 2 of 5 Saiphia Tecnology Pvt. Ltd. ITA No. 172/Ind/2024 – AY 2015-16 3. In so far as the first