GHANSHYAM TAK,NAYA GHAR AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

250 of the IT Act, 1961 for the assessment year 2020-21. The assessee has raised the following grounds :- 1. The orders passed by the authorities below in so far as they are against the appellant are opposed to law, equity, weight of evidences, facts and circumstances of the case and are therefore liable to be quashed

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

section (1B). Admittedly, in all the four appeals under consideration, the AO directed to initiate penalty u/s. 271(l)(c) of the Act in the assessment orders. Thus, the Revenue can be safely considered to have successfully passed out the first stage. (b) Recording of satisfaction at the penalty stage 14. It has been noted above that penalty proceedings

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

section (1B). Admittedly, in all the four appeals under consideration, the AO directed to initiate penalty u/s. 271(l)(c) of the Act in the assessment orders. Thus, the Revenue can be safely considered to have successfully passed out the first stage. (b) Recording of satisfaction at the penalty stage 14. It has been noted above that penalty proceedings

R P WOOD PRODUCTS PRIVATE LIMITED,AJMER vs. DCIT CENTRAL CIRCLE AJMER, JAIPUR ROAD AJMER

In the result, appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

250 of the IT Act, 1961 for the assessment year 2019-20. The assessee has raised the following grounds :- 1. The orders passed by the authorities below in so far as they are against the appellant are opposed to law, equity, weight of evidences, facts and circumstances of the case and are therefore liable to be quashed

DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR vs. SHRI KAMAL SETHIA, JAIPUR

In the result, both the appeals filed by the Revenue are dismissed

section 271(1)(c) of the Act. The initiation of penalty proceedings has happened by recording of satisfaction in the assessment order and the issuance of notice u/s 274 is thus in continuation of recording of such satisfaction and has thus to be read along DCIT, Jaipur vs. Sh. Kamal Sethia, Jaipur with the assessment order and not disjoint

SMT. SHIPRA JAIN,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, JAIPUR

In the result, the penalty so levied u/s 271(1)(c) is hereby deleted and appeals are allowed

section (1B). Admittedly, in all the four appeals under consideration, the AO directed to initiate penalty u/s. 271(l)(c) of the Act in the assessment orders. Thus, the Revenue can be safely considered to have successfully passed out the first stage. (b) Recording of satisfaction at the penalty stage 14. It has been noted above that penalty proceedings

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)

250/- 13 1178/JP/2025 2021-22 19.06.2025 Levy of penalty u/s 271E of the Act vide order dated 28.08.2023 for an amount of Rs. 6,99,87,788/- Against all these appeals of the revenue the assessee preferred cross objections which were numbered as CO/39/JP/2025 to CO/46/JP/2025. 2. As agreed by the parties the lead case of revenue is considered

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)

250/- 13 1178/JP/2025 2021-22 19.06.2025 Levy of penalty u/s 271E of the Act vide order dated 28.08.2023 for an amount of Rs. 6,99,87,788/- Against all these appeals of the revenue the assessee preferred cross objections which were numbered as CO/39/JP/2025 to CO/46/JP/2025. 2. As agreed by the parties the lead case of revenue is considered

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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross objections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross objections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

VISION JEWELLERS,JAIPUR vs. DCIT, CIRCLE-1, JAIPUR, JAIPUR

In the result the appeal of the assessee is allowed

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

section 271(1)(c). 15 VISION JEWELLERS VS DCIT CIRCLE-1, JAIPUR In view of the above, penalty levied by the ld. AO deserves to be deleted as the same has been levied in a mechanical manner and without application of mind.’’ 5. On the other hand, the ld. DR supported the 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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross objections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross\nobjections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

SHRI VIMAL CHAND SURANA,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR

In the result, appeal of the assessee is allowed

271 shall be imposed upon the assessee in respect of the undisclosed income referred to in sub-section (1). Section 158BFA(2): (2) The Assessing Officer or the Commissioner (Appeals) in the course of any proceedings under this Chapter, may direct that a person shall pay by way of penalty a sum which shall not be less than the amount

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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross objections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

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

250\n6,99,87,788\nTotal\n66,06,14,144\n24,39,82,885\n2.\nImposition of penalty u/s 271D and 271E of abovementioned acceptance\nand repayment of alleged unsecured loans\n2.1\nIn the assessment order, though the loans were added in the income of\nthe assessee, considering the same as same as \"Unexplained Business receipts\nor unaccounted income

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

250/-\n13\n1178/JP/2025\n2021-22\n19.06.2025\nLevy of penalty u/s 271E of the Act\nvide order dated 28.08.2023 for an\namount of Rs.6,99,87,788/-\nAgainst all these appeals of the revenue the assessee preferred\ncross\nobjections which were numbered as CO/39/JP/2025 to\nCO/46/JP/2025.\n2.\nAs agreed by the parties the lead case of revenue is considered in\nITA

JAMNA DEVI SHARMA,JAIPUR vs. ITO WARD 7(2), JAIPUR

In the result, both the appeals of the assessee are allowed with no orders as to costs

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

section 271(1)(c) i. Mohd. Sharif Khan vs. DCIT, in ITA. No 441/JP/2014 ii. Jai Ambey Associates vs ITO in ITA No. 801/JP/2016 In view of the above, the penalty imposed may please be quashed and the appeal of the assessee Appellant may please be allowed. On the other hand, the ld. DR relied upon the orders