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. 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

INCOME TAX OFFICER- 23(3)(1), MUMBAI, MUMBAI vs. TISYA JEWELS, MUMBAI

In the result, both the appeals of the Revenue are accordingly partly allowed

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2007-08 & Assessment Year: 2012-13 Income Tax Officer- 23(3)(1), Tisya Jewels Mumbai G-2 Sagar Fortune, 184 525A, 5Th Floor, Piramal Chambers, Vs. Waterfield Road, Bandra West, Parel, Mumbai-400012 Mumbai- 400050 Pan No. Aadft 8056 G Appellant Respondent Assessee By : Mr. Nishit Gandhi A/W Ms. Aadnya Bhandari Revenue By : Mr. Hemanshu Joshi, Cit-Dr

u/s 271(1)(c) of the Act, without appreciating judgment on the decision of Hon'ble Delhi High Court in the case of CIT Vs Atul Kumar Gupta in ITA No. 479/2014, which reinforces the Revenue Authority to impose penalties under section 271(1)(c), in the cases where the assessee fails to provide accurate and satisfactory explanations for discrepancies

INCOME TAX OFFICIER- 23(3)(1), MUMBAI, MUMBAI vs. TISYA JEWELS, MUMBAI

In the result, both the appeals of the Revenue are accordingly partly allowed

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2007-08 & Assessment Year: 2012-13 Income Tax Officer- 23(3)(1), Tisya Jewels Mumbai G-2 Sagar Fortune, 184 525A, 5Th Floor, Piramal Chambers, Vs. Waterfield Road, Bandra West, Parel, Mumbai-400012 Mumbai- 400050 Pan No. Aadft 8056 G Appellant Respondent Assessee By : Mr. Nishit Gandhi A/W Ms. Aadnya Bhandari Revenue By : Mr. Hemanshu Joshi, Cit-Dr

u/s 271(1)(c) of the Act, without appreciating judgment on the decision of Hon'ble Delhi High Court in the case of CIT Vs Atul Kumar Gupta in ITA No. 479/2014, which reinforces the Revenue Authority to impose penalties under section 271(1)(c), in the cases where the assessee fails to provide accurate and satisfactory explanations for discrepancies

DCIT CENTRAL CIRCLE 7 (1) MUMBAI , MUMBAI vs. PANTHER INVESTRADE LIMITED, MUMBAI

In the result, both the Cross appeals no

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

90,00,000/- imposed under Section 271(1)(c) of the Income Tax Act, 1961, despite the fact that the Assessee had deliberately diverted interest-bearing funds for non- business purposes for the entire year, as observed in the assessment years under consideration. 2. On the facts and circumstances of the case and in law, The learned

DCIT(CENTRAL CIRCLE)-7(1), MUMBAI vs. PANTHER INVESTRADE LIMITED, MUMBAI

In the result, both the Cross appeals no

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

90,00,000/- imposed under Section 271(1)(c) of the Income Tax Act, 1961, despite the fact that the Assessee had deliberately diverted interest-bearing funds for non- business purposes for the entire year, as observed in the assessment years under consideration. 2. On the facts and circumstances of the case and in law, The learned

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

2) he, in the course of the search 4, makes a statement under sub-section (4) of section 132 that\nany money, bullion, jewellery or other valuable article or thing found in his possession or under\nhis control, has been acquired out of his income which has not been disclosed so far in his\nreturn of income to be furnished

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT, CENTRAL CIRCLE 1(2), MUMBAI

In the result all appeals of the assesses from AY 2014-15 to AY\n2020-21 are partly allowed

2) he, in the course of the search 4, makes a statement under sub-section (4) of section 132 that\nany money, bullion, jewellery or other valuable article or thing found in his possession or under\nhis control, has been acquired out of his income which has not been disclosed so far in his\nreturn of income to be furnished

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M. JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

2,58,45,378/-.\n6.\nWhile the penalty proceedings were initiated, the assessee was\nconfronted to clarify as to why penalty should not be levied under section\n271(1)(c) of the Act. In response, the assessee made his submissions before the\nld. AO, however the contentions raised by the assessee are not enough to satisfy\nthe ld. AO, accordingly

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M JAIN,MUMBAI vs. INCOME TAX OFFICER, WARD-19(1)(1), MUMBAI

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

2,58,45,378/-. 6. While the penalty proceedings were initiated, the assessee was confronted to clarify as to why penalty should not be levied under section 271(1)(c) of the Act. In response, the assessee made his submissions before the ld. AO, however the contentions raised by the assessee are not enough to satisfy the ld. AO, accordingly

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M. JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

2,58,45,378/-. 6. While the penalty proceedings were initiated, the assessee was confronted to clarify as to why penalty should not be levied under section 271(1)(c) of the Act. In response, the assessee made his submissions before the ld. AO, however the contentions raised by the assessee are not enough to satisfy the ld. AO, accordingly

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M. JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

2,58,45,378/-. 6. While the penalty proceedings were initiated, the assessee was confronted to clarify as to why penalty should not be levied under section 271(1)(c) of the Act. In response, the assessee made his submissions before the ld. AO, however the contentions raised by the assessee are not enough to satisfy the ld. AO, accordingly

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

2,58,45,378/-.\n6.\nWhile the penalty proceedings were initiated, the assessee was\nconfronted to clarify as to why penalty should not be levied under section\n271(1)(c) of the Act. In response, the assessee made his submissions before the\nld. AO, however the contentions raised by the assessee are not enough to satisfy\nthe ld. AO, accordingly

RAJESH B, JAIN AS LEGAL OF BHANWARLAL M. JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

2,58,45,378/-.\n6.\nWhile the penalty proceedings were initiated, the assessee was\nconfronted to clarify as to why penalty should not be levied under section\n271(1)(c) of the Act. In response, the assessee made his submissions before the\nld. AO, however the contentions raised by the assessee are not enough to satisfy\nthe ld. AO, accordingly

RAJESH B. JAIN AS LEGAL HEIR OF BHANWARLAL M. JAIN,MUMBAI vs. WARD 19(1)(1), MUMBAI

2,58,45,378/-.\n6.\nWhile the penalty proceedings were initiated, the assessee was\nconfronted to clarify as to why penalty should not be levied under section\n271(1)(c) of the Act. In response, the assessee made his submissions before the\nld. AO, however the contentions raised by the assessee are not enough to satisfy\nthe ld. AO, accordingly

UNICORN INFOSERVICES PRIVATE LIMITED,MUMBAI vs. NATIONAL FACELESS APPEALS CENTRE, NEW DELHI

In the result, the regular ground raised by the

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2011-12

90,000/- u/s 271(1)(c) of the 271(1)(c) of the Income Tax Act, 1961 for concealing particulars of income. Income Tax Act, 1961 for concealing particulars of income. 2. Before us, the assessee has also filed a copy of the additional Before us, the assessee has also filed a copy of the additional Before us, the assessee

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

2) he, in the course of the search 4, makes a statement under sub-section (4) of section 132 that\nany money, bullion, jewellery or other valuable article or thing found in his possession or under\nhis control, has been acquired out of his income which has not been disclosed so far in his\nreturn of income to be furnished

TATA CONSULTANCY SERRVICES LIMITED,MUMBAI vs. DCIT-1, MUMBAI

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

penalty thereon. Section 194E of the Act belongs to a set of various provisions which deal 33 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd with tax deduction at source, without any reference to chargeability to tax under the Act of the non-resident assessee. This section is similar to sections 193 and 194 of the Act by which deductions have