DCIT-15(3)(1), MUMBAI vs. M/S. TRANSLANDS INFRASTRUCTURE DEVELOPERS P LTD, VASHI

In the result, the appeal of the revenue is dismissed

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailthe Dy. Commissioner Of Vs. M/S Translands Income-Tax, 15(3)(1), Infrastructure Developers Mumbai P. Ltd. Jn-3-14-5, Asshirwad Chs, Sector-09, Vashi, Navi Mumbai-400 703 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadct 0036 B Appellant .. Respondent

u/s. 2710 of Act". 7 DCIT vs. M/s Translands Infrastructure Developers P Ltd However, it was further held that reasonable cause given by assessee should be considered. Hon'ble High Court took note of the fact that Revenue has not shown that transaction was not bonafide transaction and was made with a view to evade tax. It was held that

DEVANG AJIT JHAVERI,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

269T during the course of assessment proceedings and then only competent authority like JCIT or Addl. CIT are authorised to impose penalty. Thus, there are two time limit envisaged in section 275, one, before the expiry of the financial year in the course of proceedings in which action for the imposition of penalty has been initiated; or second six months

ASST.COMMISSIONER OF INCOME TAX, BANDRA KURLA COMPLEX MUMBAI vs. DEVANG AJIT JAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on aforesaid terms

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

269T during the course of assessment proceedings and then only competent authority like JCIT or Addl. CIT are authorised to impose penalty. Thus, there are two time limit envisaged in section 275, one, before the expiry of the financial year in the course of proceedings in which action for the imposition of penalty has been initiated; or second six months

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Satbeer Singh Godara (Jm) & Shri Girish Agrawal (Am)

269T of the Act. Ld. Assessing Officer did not find the explanations furnished by the assessee, satisfactory and hence initiated penalty proceedings u/s. 271D and 271E of the Act. Order imposing penalty was passed on 14.11.2019. 5. In the meanwhile, assessee had contested the initiation of proceedings u/s. 147 of the Act before the Co-ordinate Bench of ITAT, Mumbai

ASST. COMMISSIONER OF INCOME TAX , BANDRA KURLA COMPLEX vs. DEVANG AJIT JHAVERI , MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

271(1)(c) and 271E of the Act. Admittedly, under\nsection 271E(2) of the Act, any penalty under section 271E(1) can\nonly be imposed by the Joint Commissioner of Income-tax (\"the\nJoint CIT\"). Consequently, the Assessing Officer referred the\nmatter to the Additional Commissioner of Income-tax.\n3. A perusal of the order dated March

DEVANG AJIT JHAVERI ,MUMBAI vs. JCIT, RANGE 17(1), MUMBAI

In the result, appeal of the Revenue is dismissed on\naforesaid terms

271(1)(c) and 271E of the Act. Admittedly, under\nsection 271E(2) of the Act, any penalty under section 271E(1) can\nonly be imposed by the Joint Commissioner of Income-tax (\"the\nJoint CIT\"). Consequently, the Assessing Officer referred the\nmatter to the Additional Commissioner of Income-tax.\n3. A perusal of the order dated March

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE 13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

269T of the Act. Ld. Assessing Officer did not find the explanations furnished by the assessee, satisfactory and hence initiated penalty proceedings u/s. 271D and 271E of the Act. Order imposing penalty was passed on 14.11.2019. 5. In the meanwhile, assessee had contested the initiation of pro- ceedings u/s. 147 of the Act before the Co-ordinate Bench of ITAT

RAVI NIRMAN NIGAM LIMITED,MUMBAI vs. CIRCLE -13(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawal

269T of the Act. Ld. Assessing Officer did not find the explanations furnished by the assessee, satisfactory and hence initiated penalty proceedings u/s. 271D and 271E of the Act. Order imposing penalty was passed on 14.11.2019. 5. In the meanwhile, assessee had contested the initiation of pro- ceedings u/s. 147 of the Act before the Co-ordinate Bench of ITAT

LIKHAMARAM,MUMBAI vs. ITO WARD 19(1)(5), MUMBAI

In the result the appeal filed by the assessee stands partly allowed

Bench: Shri Sandeep Gosain& Shri Prabhash Shankar

271(1)(c) of the Act. Thus, Insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could be levied." 7 Likhmaram, Mumbai. 7. Thus, the Hon'ble Supreme Court has affirmed the view of the Hon'ble High Court that in absence of satisfaction recorded regarding the penalty proceedings u/s 271E

PREMJI BHURALAL GALA ,MUMBAI vs. NFAC, DELHI

In the result, appeal of the assessee is allowed on the validity of the re-opening u/s

Bench: Your Honors Should Have Been Filed Within 60 Days Of Receipt Of The Order Of Cxit(A) But The Same Could Not Be Done.

penalty u/s. 271) and 271E in violation of provisions on Section 269SS and 269T. From the seized documents, he found

JIGNA ASHUTOSH BHATT ,MUMBAI vs. INCOME TAX OFFICER WARD 33(2)(1), MUMBAI

In the result the appeal of the assessee is partly allowed on merits

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokarito Ward-32(2)(1) Jigna Ashutosh Bhatt Kautilya Bhavan, I-1434, Govardhan Nagar Bandra Kurla Bldg. No. 4, Opp. Poinsur Vs. Complex, Bandra (E), Gymkhana, Kandivali Mumbai-400 051 (West), Mumbai-400 067 Pan/Gir No. Aiypb4411G (Applicant) (Respondent) Assessee By Shri Ketan L. Vajani, Ld. Ar Revenue By Shri Aditya Rai, Ld. Dr Date Of Hearing 05.01.2026 Date Of Pronouncement 06.01.2026

Penalty proceedings under sections 269SS, 269T and 271(1)(c) of the Act were also initiated. 4. Aggrieved by the reassessment order, the assessee preferred an appeal before the CIT(A). Before the CIT(A), the assessee challenged the validity of the reassessment proceedings initiated under section 147 of the Act, contending that the reopening was based on borrowed satisfaction