DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

154 taxmann.com 504 (Jaipur - Trib.) held as under:- "Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of limitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly observed that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk) vide assessment order

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed, and the

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

154 taxmann.com 504 (Jaipur - Trib.) held as under:- "Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of limitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly observed that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk) vide assessment order

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

SHRI MANOJ MOONDHRA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, both the appeals of the assessee are allowed

154 by the AO. Both the appeals of the assessee were dismissed by the ld. CIT (A) vide separate orders dated 1st November, 2017 and 1st January, 2018 and, therefore, the assessee has filed these two appeals before this Tribunal. 3. The assessee has also raised objection against the validity of initiation of proceedings under section 271AAB

SHRI MANOJ MOONDHRA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, both the appeals of the assessee are allowed

154 by the AO. Both the appeals of the assessee were dismissed by the ld. CIT (A) vide separate orders dated 1st November, 2017 and 1st January, 2018 and, therefore, the assessee has filed these two appeals before this Tribunal. 3. The assessee has also raised objection against the validity of initiation of proceedings under section 271AAB

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

SHRI MUKESH MOONDHRA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, both the appeals of the assessee are allowed

154 of the Income Tax Act, 1961 for increasing the penalty amount from Rs. 10,00,000/- to Rs. 30,00,000/- by order dated 18.11.2018 which is not subject matter of rectification. 4. The assessee craves your indulgence to add, amend or alter all or any grounds of appeal before or at the time of hearing.” 2. The facts

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n“Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has clearly\nobserved that the assessment for A.Y 2015-16 was completed by the AO (ACIT Tonk)\nvide assessment

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

154 taxmann.com 504 (Jaipur - Trib.) held as\nunder:-\n\"Thus, a penalty u/s 271D could not be imposed after the expiry of the larger period of\nlimitation. In this case, we find that the Id. JCIT in the impugned penalty order has\nclearly observed that the assessment for A.Y 2015-16 was completed by the AO (ACIT\nTonk) vide assessment

HARISH JAIN,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part

HARISH JAIN,JAIPUR vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part

RAM KISHAN VERMA,KOTA vs. PCIT (CENTRAL), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part

RAM KISHAN VERMA,KOTA vs. PCIT (CIRCLE), JAIPUR

In the result appeal of the assessee in the ITA No

section 263 of the Act do not give any power to CIT to impose his satisfaction over the satisfaction of AO as to whether the penalty proceedings are to initiated or not and if initiated under which section/clause. In our view, on examination of assessment record, the PCIT cannot direct initiation of penalty proceedings because penalty proceedings are not part