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

ALLIED PHOTOGRAPHICS INDIA LIMITED ,CHURCHGATE vs. NATIONAL FACELESS ASSESSMENT CENTER, DELHI

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 14A r.w.r 8D is not applicable. Therefore, the penalty imposed on this addition is bad in law. 4. The Id. CIT(A) failed to appreciate that the A.O had not ticked in the notice issued for levying penalty whether he intended to charge penalty for underreporting or for misreporting. The penalty notice does not clarify the same and that

LORDS INN HOTELS AND DEVELOPERS PRIVATE LIMITED,ANDHERI WEST vs. DCIT, CENTRAL CIRCLE -3(1), NARIMAN POINT

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

6)(a) of the Act, the Assessing Officer can levy penalty under Section 270A(7) of the Act at a rate of 50% of the amount of tax on under-reported income. However, in case the Assessing Officer arrives at a conclusion that the under- reporting of income is in consequence of misreporting, Assessing Officer is required to exhibit that

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

section 270A(6) of the Act. Further, we find that in the . Further, we find that in the case of Addl. CIT v. J.K. D’s Costa (supra), the Hon’ble High Court case of Addl. CIT v. J.K. D’s Costa (supra), the Hon’ble High Court case of Addl. CIT v. J.K. D’s Costa (supra

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

271(1)(c) on the same ground. Therefore our decision in AY 2015- 11 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16 is mutatis mutandis applicable to AY 2016-17 also. Accordingly we direct the AO to delete the penalty for AY 2016-17. ITA No.3753/Mum/2024 – AY 2017-18 12. For AY 2017-18 the assessee filed

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT 3(1)(1),MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD, MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

u/s 271(1)(c) of the Act is upheld. Accordingly, the grounds of the revenue are dismissed. 8. In the result, appeal of the revenue is dismissed” 18. In view of the above, we hold that the order passed by the Learned CIT(A) deleting penalty of INR. INR.1,76,210/- levied under Section 271

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

271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess depreciation is also cancelled. The relevant grounds of the appeal of the assessee are allowed.” 5. With respect to the penalty proceedings for AYs 2017–18 to 2019–20, the penalties were levied under section 270A