SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

271(1)(c) of the Act are fulfilled. In view of\nthe above, the penalty in respect of interest and the excess\ndepreciation is also cancelled. The relevant grounds of the appeal of\nthe assessee are allowed.\n8. The grounds in respect of assessment year 2015-16 are\nreproduced as under:\n1. On the facts and circumstances of the case

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

271(1)(c) of the Act, but being pari-materia,\nis applicable over the facts of this case also. However, we do not\nagree with the contention of the Ld. Counsel for the assessee for the\nreason that penalty is levied on charge of undisclosed income\ndefined under the said section and rate of the penalty depends on\nthe other

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

271(1)(c) of the Act, but being pari-materia,\nis applicable over the facts of this case also. However, we do not\nagree with the contention of the Ld. Counsel for the assessee for the\nreason that penalty is levied on charge of undisclosed income\ndefined under the said section and rate of the penalty depends on\nthe other

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-3(4), MUMBAI, MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

Accordingly.\n7. To sum-up, these Revenue's twin appeals ITA.Nos.1875 & 1872/Mum./2024 and assessee's cross objections C.O.Nos.88 & 89/MUM./2024 are dismissed in above terms

iii) of sub-section (1) of section 271 of the Act, penalty for concealment of income or furnishing inaccurate particulars of income is determined based on the \"amount of tax sought to be evaded\" which has been defined inter alia, as the difference between the tax due on the income assessed and the tax which would have been chargeable

GENERAL ELECTRIC INTERNATIONAL INC.,GURGAON vs. DCIT, INTERNATIONAL TAXATION CIRCLE 2(3)(2), MUMBAI

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act on account on furnishing of inaccurate particulars of income. b) The Appellant has provided bona fide explanation/reasonable cause in respect of additional income of INR 1,95,86,904 which has been suo moto offered to tax. c) The Appellant has provided bona fide explanation/reasonable cause in respect of 2 taxability of soft

UNICORN INFOSERVICES PRIVATE LIMITED,MUMBAI vs. NATIONAL FACELESS APPEALS CENTRE, NEW DELHI

In the result, the regular ground raised by the

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2011-12

iii. 100% of tax is Rs. 3,89,340/ 100% of tax is Rs. 3,89,340/-. iv. 300% of tax is Rs. 11,68,020/ 300% of tax is Rs. 11,68,020/-.” 3.2 The Ld. CIT(A) upheld penalty observing as under: The Ld. CIT(A) upheld penalty observing as under: The Ld. CIT(A) upheld penalty observing

ANJIS DEVELOPERS PRIVATE LIMITED,MUMBAI vs. PRINCIPLE CIT-5,MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2017-18 Anjis Developers Private Limited, Pcit-5, 2Nd Floor, Soham Apartments, Room No. 515, 5Th Floor, 208, Walkeshwar Road, Teen Vs. Aayakar Bhavan, Mk. Batti, Road, Mumbai-400006. Mumbai-400020. Pan No. Aaaca 6022 H Appellant Respondent : Assessee By S. Sriram/Dinesh Kukreja/Ssnyaknavedie Revenue By : Shri Chetan Kacha, Dr : Date Of Hearing 25/11/2022 Date Of Pronouncement : 20/02/2023

142 ITR 606 (Delhi) 3. CIT v. Nihal Chand Rekyan (20001 242 ITTR 45 (Delhi). 3. CIT v. Nihal Chand Rekyan (20001 242 ITTR 45 (Delhi). 3. CIT v. Nihal Chand Rekyan (20001 242 ITTR 45 (Delhi). 8. Having heard the leamed counsel for the parties we find that 8. Having heard the leamed counsel for the parties we find

NIYATI SUTARIA JEMES ,MUMBAI vs. INCOME TAX DEPARTMENT , MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailniyati Sutaria James, 302 Parimal Premises, 17Th Road, Khar West, Mumbai – 400052 ............... Appellant Pan : Ahipj7649B V/S Ito, Ward – 23(2)(1), Piramal Chambers, Parel ……………… Respondent Mumbai - 400012

u/s 142(1). The appellant submits that on the facts and circumstances of the case and in law the CIT(A) erred in holding that since the notices/ letters/ communication have been served on the e-mail id registered in the income tax portal by the assessee herself, it should not be construed as 'reasonable cause' as per the provision

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

142(1) were issued calling for details such as nature of business, bank statements, Form 26AS, partnership deed, audit report in Forms 3CB and 3CD and other relevant information. 4. After considering the material placed on record, the assessment was completed under section 143(3) read with section 147 and section 144B of the Act vide order dated 27.03.2022 determining

RANJIT PATHAK,MUMBAI vs. DCIT CIRCLE 42(3)(1), MUMBAI

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

142(1) of the Act dated 17.08.2021,\n23.12.2021, 04.02.2022 and 15.02.2022.\n2.2 Subsequently, vide separate orders, the AO levied penalty of\nRs.40,000/- under Section 271(1)(b) dated 16.09.2022(i.e.,\nRs.10,000/- for each of the four defaults) and penalty of\nRs.17,30,000/- under Section 271(1)(c) dated 27.09.2022.\n2.3 The assessee preferred an appeal against

RANJIT PATHAK ,MUMBAI vs. DCIT CIRCLE 42(3)(1), MUMBAI

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

142(1) of the Act dated 17.08.2021,\n23.12.2021, 04.02.2022 and 15.02.2022.\n\n2.2 Subsequently, vide separate orders, the AO levied penalty of\nRs.40,000/- under Section 271(1)(b) dated 16.09.2022(i.e.,\nRs.10,000/- for each of the four defaults) and penalty of\nRs.17,30,000/- under Section 271(1)(c) dated 27.09.2022.\n\n2.3 The assessee preferred an appeal

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD -1 PALGHAR , THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

III. Appeal against Penalty u/s 272A(1)(d) (ITA No.7677/MUM/2025) 1. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay on the ground that the assessee had no sufficient cause of explanation for the delay in filing the appeal, without appreciating the facts

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN,MUMBAI vs. ITO WARD 1 PALGHAR, THANE

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

III. Appeal against Penalty u/s 272A(1)(d) (ITA No.7677/MUM/2025) 1. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay on the ground that the assessee had no sufficient cause of explanation for the delay in filing the appeal, without appreciating the facts

RAKESH JAIN AS THE LEGAL HEIR OF BHAWARLAL SHRILAL JAIN ,MUMBAI vs. ITO WARD-1 PALGHAR , MUMBAI

In the result, all four appeals of the assessee stand allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 7674/Mum/2025 (Assessment Year: 2013-14) 2. Ita No. 7675/Mum/2025 (Assessment Year: 2013-14) 3. Ita No. 7676/Mum/2025 (Assessment Year: 2013-14) & 4. Ita No. 7677/Mum/2025 (Assessment Year: 2013-14) Rakesh Jain As Legal Ito Ward-1, Heir Of Bhawarlal Shrilal Bidco Road, Jain, Vs. Palghar, Shop 5, Vaibhav Complex, Maharashtra – Irani Road, Malyan, 401 404 Dahanu Road, Thane – 401602, Maharashtra. Pan/Gir No. Abjpj5270F (Applicant) (Respondent) Assessee By Shri Suchek Anchaliya, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 05.02.2026 Date Of Pronouncement 09.02.2026 आदेश / Order Per Makarand Vasant Mahadeokar, Am: These Four Appeals Are Directed Against Separate Orders Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], All Dated 26.09.2025 & 18.09.2025, For Assessment Year 2013– 14. Since The Issues Involved In All The Appeals Arise Out Of The Same Set Of Facts & Relate To Proceedings Initiated In The Name Of Late Shri Bhawarlal Shrilal Jain, These Appeals Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience & Brevity.

III. Appeal against Penalty u/s 272A(1)(d) (ITA No.7677/MUM/2025) 1. On the facts and in the circumstances of the case in law, the Ld. CIT(A)/NFAC, erred in rejecting the condonation of the delay on the ground that the assessee had no sufficient cause of explanation for the delay in filing the appeal, without appreciating the facts