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53 results for “penalty u/s 271”+ Section 56(2)(viia)clear

Sorted by relevance

Mumbai53Nagpur7Varanasi6Delhi5Kolkata3Chandigarh2Pune1Raipur1

Key Topics

Section 14A48Penalty30Section 80P19Section 143(3)16Addition to Income15Section 6810Deduction10Transfer Pricing10Permanent Establishment

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

ITA 2651/MUM/2023[2013-14]Status: DisposedITAT Mumbai05 Apr 2024AY 2013-14
For Appellant: \nShri. Madhur AgrawalFor Respondent: \nShri. Ajay Chandra &
Section 143(1)Section 143(3)Section 147Section 68

viia)/(viib) from A.Y.2013-14.\nThus such an addition cannot be made u/s 68 of the Act.\n21.\nThe Ld. AR of the appellant has further contended that the\ntransaction is a commercial transaction wherein exiting shareholders\nand independent investors have agreed to participate in business\nventure based on their own understanding of the industry, risk-\nreward matrix and other relevant

ACIT, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

Showing 1–20 of 53 · Page 1 of 3

10
Section 143(1)9
Section 80P(4)9
Section 36(1)(viia)6

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

ITA 2635/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Apr 2024AY 2012-13
For Appellant: \nShri. Madhur AgrawalFor Respondent: \nShri. Ajay Chandra &
Section 143(1)Section 143(3)Section 147Section 68

viia)/(viib) from A.Y.2013-14.\nThus such an addition cannot be made u/s 68 of the Act.\n21. The Ld. AR of the appellant has further contended that the\ntransaction is a commercial transaction wherein exiting shareholders\nand independent investors have agreed to participate in business\nventure based on their own understanding of the industry, risk-\nreward matrix and other relevant

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

ITA 2646/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Apr 2024AY 2017-18
For Appellant: \nShri. Madhur AgrawalFor Respondent: \nShri. Ajay Chandra &
Section 143(1)Section 143(3)Section 147Section 68

viia)/(viib) from A.Y.2013-14.\nThus such an addition cannot be made u/s 68 of the Act.\n21.\nThe Ld. AR of the appellant has further contended that the\ntransaction is a commercial transaction wherein exiting shareholders\nand independent investors have agreed to participate in business\nventure based on their own understanding of the industry, risk-\nreward matrix and other relevant

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 698/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Aug 2024AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 697/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Aug 2024AY 2014-15

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY LTD,NAVI MUMBAI vs. WARD 28(1)(3), NAVI MUMBAI

In the result, the assessee‟s appeal ITA NO

ITA 699/MUM/2024[2018-19]Status: DisposedITAT Mumbai07 Aug 2024AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 250Section 271(1)(C)Section 80PSection 80P(4)

Penalty proceedings u/s. 271(1)(C) of the Act were separately initiated for furnishing inaccurate particulars of income. 2. (ii) Aggrieved by the assessment order, assessee preferred an appeal before learned CIT(A), who confirmed assessment order, holding that the assessee is neither a primary agricultural credit society nor primary agricultural development bank but is a co–operative bank

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

ITA 2653/MUM/2023[2011-12]Status: DisposedITAT Mumbai05 Apr 2024AY 2011-12
For Respondent: \nShri. Madhur Agrawal
Section 143(1)Section 143(3)Section 147Section 68

viia)/(viib) from A.Y.2013-14.\nThus such an addition cannot be made u/s 68 of the Act.\n21.\nThe Ld. AR of the appellant has further contended that the\ntransaction is a commercial transaction wherein exiting shareholders\nand independent investors have agreed to participate in business\nventure based on their own understanding of the industry, risk-\nreward matrix and other relevant

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. AADHAAR WHOLESALE TRADING AND DISTRIBUTION LTD., MUMBAI

In the result, appeals of revenue are dismissed and cross\nobjection of the assessee is allowed

ITA 2650/MUM/2023[2014]Status: DisposedITAT Mumbai05 Apr 2024
For Appellant: \nShri. Madhur AgrawalFor Respondent: \nShri. Ajay Chandra &
Section 143(1)Section 143(3)Section 147Section 68

viia)/(viib) from A.Y.2013-14.\nThus such an addition cannot be made u/s 68 of the Act.\n21.\nThe Ld. AR of the appellant has further contended that the\ntransaction is a commercial transaction wherein exiting shareholders\nand independent investors have agreed to participate in business\nventure based on their own understanding of the industry, risk-\nreward matrix and other relevant

DCIT - 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORARTION LTD., MUMBAI

ITA 2862/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Jan 2025AY 2012-13

u/s. \n36(1)(viia) of the Act. \n\n29. This issue arises in the following appeals:\n\n Assessment year \nGround No. in \nAssessee's appeal \nGround No. in \nRevenue's appeal \n2018-19 \n- \n2 \n2019-20 \n- \n2 \n2020-21 \n- \n2 \n\n29. 1. In respect of this issue, assessee in its books of account had made

ADDL CIT RG 1(1), MUMBAI vs. HDFC LTD, MUMBAI

ITA 3785/MUM/2009[2004-05]Status: DisposedITAT Mumbai28 Jan 2025AY 2004-05

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table, all the appeals arise out of assessment orders passed u/s. 143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- 03 up to 2020-21. Since, similar issues are arising in several years, before dealing with

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

ITA 2867/MUM/2012[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table, all the appeals arise out of assessment orders passed u/s. 143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- 03 up to 2020-21. Since, similar issues are arising in several years, before dealing with

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

ITA 4313/MUM/2010[2002-03]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-03

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table, all the appeals arise out of assessment orders passed u/s. 143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- 03 up to 2020-21. Since, similar issues are arising in several years, before dealing with

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

ITA 5033/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

271(1)(c)] 2. Except for appeals mentioned at Sr. Nos. 24 and 39 to 42 in the above table, all the appeals arise out of assessment orders passed u/s. 143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- 03 up to 2020-21. Since, similar issues are arising in several years, before dealing with

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

ITA 2665/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jan 2025AY 2015-16

271(1)(c) | 2006-07 | \n2. Except for appeals mentioned at Sr. Nos.24 and 39 to 42 in the \nabove table, all the appeals arise out of assessment orders passed u/s. \n143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002-\n03 up to 2020-21. Since, similar issues are arising in several years, \nbefore dealing

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

ITA 2866/MUM/2012[2005-06]Status: DisposedITAT Mumbai28 Jan 2025AY 2005-06

271(1)(c) 2006-07 \n2. Except for appeals mentioned at Sr. Nos.24 and 39 to 42 in the \nabove table, all the appeals arise out of assessment orders passed u/s. \n143(3) of the Income-tax Act, 1961 (‘the Act’) for assessment years 2002- \n03 up to 2020-21. Since, similar issues are arising in several years, \nbefore dealing

CIDCO EMPLOYEES CO-OP. CREDIT SOCIETY,MUMBAI vs. ITO, WARD-28(1)(3), MUMBAI

In the result, Tax Appeals are dismissed

ITA 600/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 Jun 2024AY 2012-13

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2012-13 M/S. Cidco Employees Ward 28(1)(3), 3Rd Floor, Co. Op. Credit Society Ground Floor, Tower No. 6, Vs. Cidco Bhavan, Vashi Railway Station, Cbd- Belapur, Commercial Complex, Navi Mumbai- 400614. Mumbai- 400703. Pan: Aaaac2230N (Appellant) (Respondent) Present For : Assessee By : Shri Bhupendra Shah, A.R. Revenue By : Shri R. R. Makwana- Sr. D.R.

For Appellant: Shri Bhupendra Shah, A.RFor Respondent: Shri R. R. Makwana- SR. D.R
Section 143(1)Section 143(3)Section 148Section 2(24)(viia)Section 234BSection 250Section 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

penalty proceedings under section 271(1)(c) of the Act. [B] General:-  The appellant reserve rights to add alter or delete any portion of this appeal before its conclusion.  This appeal is filed late and delay may be condoned  A detailed paper book will be filed at the time of hearing.” 3. The facts of the case, in brief

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2049/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Section 57(iii) and find that ld.\nUnder the said section, Assessing Officer has no power to bifurcate on\npro-rata basis and deduct a part of it from the gross dividend income.\nThere is no scope for any estimation of expenditure and hence no scope\n53\nHDFC Bank Ltd.\nITA No.4315/MUM/2007 and Ors.\nAYs

DCIT 2(3)(1), MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3371/MUM/2023[2018-19]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-19

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

viia) Disallowance of ESOP of Ground No.5 expenses 2. We will first consider the assessee's appeal for adjudication. ITA No. 1783/Mum/2023 – AY 2016-17 Disallowance under section 14A – Ground No.1 2. During the year under consideration, the assessee had earned exempt income to the tune of Rs. 480,76,49,494/-. The Assessing Officer (AO) called on the assessee

DCIT-2(3)(1), MUMBAI, MUMBAI vs. HDFC BANK LIMITED, MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 3375/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Jan 2024AY 2016-17

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

viia) Disallowance of ESOP of Ground No.5 expenses 2. We will first consider the assessee's appeal for adjudication. ITA No. 1783/Mum/2023 – AY 2016-17 Disallowance under section 14A – Ground No.1 2. During the year under consideration, the assessee had earned exempt income to the tune of Rs. 480,76,49,494/-. The Assessing Officer (AO) called on the assessee

HDFC BANK LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX-2(3)(1), MUMBAI

In the result, the assessee's appeal for AY 2016-17 to AY 2018-19 is allowed and the Revenue's appeal for AY 2016-17 to 2018-19 is dismissed

ITA 1785/MUM/2023[2018-2019]Status: DisposedITAT Mumbai24 Jan 2024AY 2018-2019

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar a/w ShriFor Respondent: Shri Biswanath Das, CIT-DR
Section 14ASection 36(1)(viia)

viia) Disallowance of ESOP of Ground No.5 expenses 2. We will first consider the assessee's appeal for adjudication. ITA No. 1783/Mum/2023 – AY 2016-17 Disallowance under section 14A – Ground No.1 2. During the year under consideration, the assessee had earned exempt income to the tune of Rs. 480,76,49,494/-. The Assessing Officer (AO) called on the assessee