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 is not leviable. There is no scope to levy penalty under the said section. Accordingly, in the given set of facts, the penalty levied u/s.271(1)(c) is deleted. Ground raised by the assessee is allowed.” 7.4 In view of the facts of the case and the decisions of the Hon’ble ITAT referred above, penalty

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 is not leviable. There is no scope to levy penalty under the said section. Accordingly, in the given set of facts, the penalty levied u/s.271(1)(c) is deleted. Ground raised by the assessee is allowed.” 7.4 In view of the facts of the case and the decisions of the Hon’ble ITAT referred above, penalty

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 is not leviable. There is no scope to levy penalty under the said section. Accordingly, in the given set of facts, the penalty levied u/s.271(1)(c) is deleted. Ground raised by the assessee is allowed.” 7.4 In view of the facts of the case and the decisions of the Hon’ble ITAT referred above, penalty

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 is not leviable. There is no scope to levy penalty under the said section. Accordingly, in the given set of facts, the penalty levied u/s.271(1)(c) is deleted. Ground raised by the assessee is allowed.” 7.4 In view of the facts of the case and the decisions of the Hon’ble ITAT referred above, penalty

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 is not leviable. There is no scope to levy penalty under the said section. Accordingly, in the given set of facts, the penalty levied u/s.271(1)(c) is deleted. Ground raised by the assessee is allowed.” 7.4 In view of the facts of the case and the decisions of the Hon’ble ITAT referred above, penalty

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

69C: On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax Appeals erred in upholding the action of the Assessing Officer of levying the penalty of Rs.29,02,020/- u/s 271(1)(c) by treating the adhoc addition of Rs. 86,21,564/- on the basis of peak balance

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. INCOME TAX OFFICER, MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

69C of the Act and added the same to the total income of the Assessee. The Assessing Officer simultaneously also initiated penalty proceedings for concealment of particulars of income and issued notice dated 30.03.2014 under section 274 read with section 271(1)(c) of the Act for concealment of particulars of income or furnishing of inaccurate particulars of income

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. ITO WARD 30(1)(2), MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

69C of the Act and added the same to the total income of the Assessee. The Assessing Officer simultaneously also initiated penalty proceedings for concealment of particulars of income and issued notice dated 30.03.2014 under section 274 read with section 271(1)(c) of the Act for concealment of particulars of income or furnishing of inaccurate particulars of income

CHIRAGKUMAR RAJENDRABHAI SHAH,MUMBAI vs. ITO WARD 30(1)(2), MUMBAI

In the result, ITA No. 7130/M/2025 is allowed

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

69C of the Act and added the same to the total income of the Assessee. The Assessing Officer simultaneously also initiated penalty proceedings for concealment of particulars of income and issued notice dated 30.03.2014 under section 274 read with section 271(1)(c) of the Act for concealment of particulars of income or furnishing of inaccurate particulars of income

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER vs. CHETAN PRAVIN CHITALIA, MUMBAI

In the result, appeal of the revenue is dismissed

Bench: Shri Saktijit Dey, Vice- & Shri Bijayananda Pruseth

section 271(1)(c), in the cases where the assessee fails to provide accurate and satisfactory explanations for discrepancies in their accounts even if the addition is made of estimate basis? 9. The Tax- Effect involved in the instant case is Rs.3,91,799/-, which is below the prescribed limit as per CBDT's Circular F.No.279/Misc. 142/2007-ITJ(Pt) amended

M/S.ALLIED DIGITAL SERVICES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(3), MUMBAI, MUMBAI

In the result the Assessee‟s Appeal is allowed

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11 M/S. Allied Digital Services Deputy Commissioner Of Limited, Income Tax, Central 808, 8Th Floor, Mafatlal Centre, Circile 1(3), 905,9Th Floor, Nariman Point, Vs. Mumbai – 400021. Old Cgo Building, Pan – Aaaca5509K Pratishtha Bhavan, M.K. Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Ms. Vinita Shah, Ld. A.R. Revenue By : Shri Surendra Mohan, Sr. D.R. Date Of Hearing : 12.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short „The Act‟) For The A.Y. 20101-11. 2. In The Instant Case, The Ao Vide Assessment Order Dated 28.03.2013 Under Section 143 (3) R.W.S. 153(A) Of The Act Has Made The Additions Of Rs.5,35,91,882/- & Rs.1,25,66,049/- On Account Of Disallowances Under Section 69C Of The Act & Section 2 M/S. Allied Digital Services Limited

69C of the Act and Section 2 M/s. Allied Digital Services Limited 14A of the Act read with Rule 8 D of the Income Tax Rule, 1962 (in short, “Rules”) respectively. The AO while making the addition of Rs.5,35,91,882/- also recorded the satisfaction in the assessment order for initiation of penalty proceedings under Section 271

INCOME TAX OFFICER 19.1.1, PIRAMAL CHAMBER LAL BAUG vs. A J DIAM, MUMBAI

In the result, appeal filed by the revenue is dismissed in the above terms

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanito-19(1)(1), Mumbai A. J. Diam Room No. 501, Piramal Chamber, Vs. 304, 3Rd Floor, Deccan Vikas Chs Lalbaug, Mumbai-400 012. Ltd. 584/1/584, Vithalbhai Patel Road, Kothachiwadi, Mumbai- 400 004 Pan: Aaofa4830G (Appellant) (Respondent)

section 271(1)(c) and explanation thereto, as held in the case of K.P. Madhusudhan Vs. CIT reported in 251 ITR 99 (SC) ? 3. Whether on the facts and circumstances of the case and in law, the decision of the Ld. CIT(A) is right in deleting the penalty, in view of the decision of the Hon'ble High Court

M/S. PANKAJ ENTERPRISES.,MUMBAI vs. ACIT, CC-2(2), MUMBAI

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2012-13

section 271(1)(c) of the 2 M/s. Pankaj Enterprises Income Tax Act, 1961 (for short ‘the Act’) by raising grounds inter-alia that: “1. Ld. CIT (A) erred in directing to recomputed penalty impossible u/s 271(1)(c) after computing capital gain on Development Agreement as per directions of Hon ITAT in its Appellate order without considering the fact

SHRI NARENDRA S SHAH,MUM vs. DCIT, CC-2(2), , MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

section 68 section 68 of the Act and some unexplained expenditure under d some unexplained expenditure under section d some unexplained expenditure under 69C of the Act and also disallowed interest of Rs.5,73,193/ of the Act and also disallowed interest of Rs.5,73,193/- of the Act and also disallowed interest of Rs.5,73,193/ , paid on unsecured

SHRI NARENDRA S SHAH,MUM vs. DCIT, CC-2(2),, MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

section 68 section 68 of the Act and some unexplained expenditure under d some unexplained expenditure under section d some unexplained expenditure under 69C of the Act and also disallowed interest of Rs.5,73,193/ of the Act and also disallowed interest of Rs.5,73,193/- of the Act and also disallowed interest of Rs.5,73,193/ , paid on unsecured

SHRI NARENDRA S SHAH ,MUMBAI vs. DCIT, CEN CIR-(2), , MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

section 68 section 68 of the Act and some unexplained expenditure under d some unexplained expenditure under section d some unexplained expenditure under 69C of the Act and also disallowed interest of Rs.5,73,193/ of the Act and also disallowed interest of Rs.5,73,193/- of the Act and also disallowed interest of Rs.5,73,193/ , paid on unsecured

DCIT, CC-2(2),, MUM vs. SHRI NARENDRA S SHAH, MUMBAI

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

section 68 section 68 of the Act and some unexplained expenditure under d some unexplained expenditure under section d some unexplained expenditure under 69C of the Act and also disallowed interest of Rs.5,73,193/ of the Act and also disallowed interest of Rs.5,73,193/- of the Act and also disallowed interest of Rs.5,73,193/ , paid on unsecured

DCIT, CC-2(2), , MUM vs. SHRI NARENDRA S SHAH, MUM

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant ()

section 68 section 68 of the Act and some unexplained expenditure under d some unexplained expenditure under section d some unexplained expenditure under 69C of the Act and also disallowed interest of Rs.5,73,193/ of the Act and also disallowed interest of Rs.5,73,193/- of the Act and also disallowed interest of Rs.5,73,193/ , paid on unsecured