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)

250 of the Act is erroneous, devoid of facts and contrary to the provisions of the law and accordingly, liable to be quashed. 2. On the facts and in the circumstances of the case and in law, the penalty order dated 26 March 2022 passed under section 271(1)(c) of the Act in consequence of the invalid assessment order

PRIORITY JEWELS PRIVATE LIMITED,MUMBAI vs. COMMISSIONER OF INCOME TAX (A), APPEALS

In the result, the appeal of the assessee bearing ITA 3196/Mum/2024 is\nallowed

6) The order of the Commissioner (Appeals) disposing of the appeal shall be in\nwriting and shall state the points for determination, the decision thereon and\nthe;\"reason for the decision.\n(€A) In every appeal, the Commissioner (Appeals), where it is possible, may hear\nand decide such appeal within a period of one year from

MORAJ BUILDING CONCEPTS PRIVATE LIMITED,NAVI MUMBAI vs. INCOME TAX OFFICER CENTRAL CIRCLE 5(2), MUMBAI

The appeals are dismissed as having been rendered infructuous

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

u/s 271(1)(c) of the Income Tax Act, 1961. 7. The total income sought to be evaded is Rs.1.91,184/-. As per the provisions of section 271(1)(c): Assessment Year 2014-2015, 2015-2016 & 2016-2017 Minimum penalty @100% of tax sought to be evaded : Rs.59,076/- Minimum penalty @300% of tax sought to be evaded : Rs.1

MORAJ BUILDING CONCEPTS PRIVATE LIMITED,NAVI MUMBAI vs. INCOME TAX OFFICER, CENTRAL CIRCLE 5(2), MUMBAI

The appeals are dismissed as having been rendered infructuous

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

u/s 271(1)(c) of the Income Tax Act, 1961. 7. The total income sought to be evaded is Rs.1.91,184/-. As per the provisions of section 271(1)(c): Assessment Year 2014-2015, 2015-2016 & 2016-2017 Minimum penalty @100% of tax sought to be evaded : Rs.59,076/- Minimum penalty @300% of tax sought to be evaded : Rs.1

MORAJ BUILDING CONCEPTS PRIVATE LIMITED,NAVI MUMBAI vs. INCOME TAX OFFICER, CENTRAL CIRCLE 5(2), MUMBAI

The appeals are dismissed as having been rendered infructuous

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

u/s 271(1)(c) of the Income Tax Act, 1961. 7. The total income sought to be evaded is Rs.1.91,184/-. As per the provisions of section 271(1)(c): Assessment Year 2014-2015, 2015-2016 & 2016-2017 Minimum penalty @100% of tax sought to be evaded : Rs.59,076/- Minimum penalty @300% of tax sought to be evaded : Rs.1

DCIT, CENTRAL CIRCLE - 7(1), MUMBAI , MUMBAI vs. TRIUMPH SECURITIES LTD, MUMBAI

In the result, the appeal of the revenue bearing ITA No

250 of the Income-tax Act, 1961 (for brevity, ‘the Act'), date\nof order 28/12/2023 for A.Y. 2003-04. The impugned order was emanated from\nthe order of the Learned Deputy Commissioner of Income-tax, Central Circle-\n7(1),Mumbai (for brevity the “Ld.AO”) passed under section 271(1)(c)of the Act,\ndate of order 30/03/2019.\n2.\nThe revenue

FABRIKANT TRADING (INDIA) PRIVATE LIMITED,MUMBAI vs. DCIT CIRCLE 5(1)(1), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], which in turn arose from the penalty order passed under section 271(1)(c) of the Act, for the assessment year 2007–08. Fabrikant Trading (India) Pvt. Ltd. 2. In its appeal, the assessee

RAJU MOHAN GURNANI,NAVI MUMBAI vs. CENTRAL CIRCLE 5(2), MUMBAI

In the result, all three appeals of the assessee are allowed

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 246/Mum/2025 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 247/Mum/2025 (निर्धारण वर्ा / Assessment Year :2015-16) आयकर अपील सं./Ita No. 248/Mum/2025 (निर्धारण वर्ा / Assessment Year :2016-17) Raju Mohan Gurnani V/S. Ito, Central Circle 5(2) बिधम Flat No. 2101, Moraj Casa Room No. 427, 4Th Floor, Grande, Plot No. 57, Sector Kautilya Bhavan, Bandra 17, Koperkhairne Kurla Complex, Bandra Maharashtra-410209 East, Maharashtra-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpg9103B Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: None रधजस्व की ओर से /Revenue By: Shri R. R. Makwana

250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Years [A.Ys.] 2014-15, 2015-16 & 2016-17. 2. The assessee has raised the following grounds of appeal: AY 2014-15 “GROUND NO. 1: LEVY OF PENALTY U/S 271(1)(c) OF RS. 91,360/- (a) The Id. CIT(A) erred in law and on facts

RAJU MOHAN GURNANI,NAVI MUMBAI vs. INCOME TAX OFFICER, CENTRAL CIRCLE 5(2), MUMBAI

In the result, all three appeals of the assessee are allowed

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 246/Mum/2025 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 247/Mum/2025 (निर्धारण वर्ा / Assessment Year :2015-16) आयकर अपील सं./Ita No. 248/Mum/2025 (निर्धारण वर्ा / Assessment Year :2016-17) Raju Mohan Gurnani V/S. Ito, Central Circle 5(2) बिधम Flat No. 2101, Moraj Casa Room No. 427, 4Th Floor, Grande, Plot No. 57, Sector Kautilya Bhavan, Bandra 17, Koperkhairne Kurla Complex, Bandra Maharashtra-410209 East, Maharashtra-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpg9103B Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: None रधजस्व की ओर से /Revenue By: Shri R. R. Makwana

250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Years [A.Ys.] 2014-15, 2015-16 & 2016-17. 2. The assessee has raised the following grounds of appeal: AY 2014-15 “GROUND NO. 1: LEVY OF PENALTY U/S 271(1)(c) OF RS. 91,360/- (a) The Id. CIT(A) erred in law and on facts

RAJU MOHAN GURNANI,NAVI MUMBAI vs. INCOME TAX OFFICER, CENTRAL CIRCLE 5(2), MUMBAI

In the result, all three appeals of the assessee are allowed

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 246/Mum/2025 (निर्धारण वर्ा / Assessment Year :2014-15) आयकर अपील सं./Ita No. 247/Mum/2025 (निर्धारण वर्ा / Assessment Year :2015-16) आयकर अपील सं./Ita No. 248/Mum/2025 (निर्धारण वर्ा / Assessment Year :2016-17) Raju Mohan Gurnani V/S. Ito, Central Circle 5(2) बिधम Flat No. 2101, Moraj Casa Room No. 427, 4Th Floor, Grande, Plot No. 57, Sector Kautilya Bhavan, Bandra 17, Koperkhairne Kurla Complex, Bandra Maharashtra-410209 East, Maharashtra-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aalpg9103B Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: None रधजस्व की ओर से /Revenue By: Shri R. R. Makwana

250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Years [A.Ys.] 2014-15, 2015-16 & 2016-17. 2. The assessee has raised the following grounds of appeal: AY 2014-15 “GROUND NO. 1: LEVY OF PENALTY U/S 271(1)(c) OF RS. 91,360/- (a) The Id. CIT(A) erred in law and on facts

M/S SUPERTECH CONSTRUCTION COMPANY,MUMBAI vs. ACIT 27 (3), MUMBAI

In the result, appeal preferred by the Assessee is allowed

u/s 271(1)(c) on estimated addition is bad-in-law.” When the appeal was taken for hearing none present on behalf of the 3. Appellant. On perusal of the memorandum of appeal, we find that the solitary issue raised in the present appeal pertains to the levy of penalty under Section 271(1)(c) of the Act. We have

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT -CENTRAL CIRCLE -1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount

TRIG DETECTIVES PVT LTD ,MUMBAI vs. DCIT-CENTRAL CIRCLE 1(2), MUMBAI

In the result, the appeals filed by the assessee bearing ITA Nos

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

250/- Rs.2,57,98,917/- made by the Ld. AO. Finally, the notice u/s 274 r.w.s. 271(1)(c) of the Act was issued and the penalty was levied amount to Rs.83,70,459/- i.e. 100% of tax sought to be evaded. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A) granted the relief amount