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

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

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. 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

SHYAM KUMAR SADASHIVAN PILLAI,MUMBAI vs. INCOME TAX OFFICER, CIRCLE 27(3)(1), NAVI MUMBAI

In the result, the appeal is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

1)(b) is not warranted. The ld DR in this regard argued that the reassessment proceedings were completed under section 147 r.w.s.144 and therefore the assessee cannot take the plea that the details submitted thereby not warranting penalty. However we are unable to appreciate this contention of the ld DR since the penalty under section 271

DWARKA CEMENT WORKS LIMITED(CONVERTED INTO DWARKA CEMENT WORKS LLP W.E.F 15-09-2022),MUMBAI vs. THE INCOME TAX OFFICER,WARD-6(2)(1),MUMBAI, MUMBAI

In the result, the appeal of the assessee is allowed

reassessment order, the Assessing Officer held\nthat the reduction in loss from Rs. 1,15,25,958/- as originally\nreturned to Rs. (-) 30,057/- represented concealment of income to\nthe extent of Rs. 1,14,95,901/-\n6. On the aforesaid basis, the Assessing Officer initiated and\nsubsequently levied penalty under section 271

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

reassessed the income of the assessee at Rs.15,90,000 by making addition towards 25% gross profit on alleged bogus purchase made from hawala dealers. Thereafter, the AO levied penalty under section 271(1

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

reassessed the income of the assessee at Rs.15,90,000 by making addition towards 25% gross profit on alleged bogus purchase made from hawala dealers. Thereafter, the AO levied penalty under section 271(1

PUMPKIN PICTURES PRIVATE LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -2, THANE

In the result, the appeal by the assessee is dismissed

Bench: Om Prakash Kant & Shri Sandeep Singh Karhail

reassessment proceedings under section 147 of the Act was sent to all four directors of the assessee company. Thereafter, notice under section 142(1) along with a specific questionnaire was also issued to the assessee on 28/09/2018. In response, the Authorised Representative of the assessee attended the proceedings and explained the case and also assured the AO that the details

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

271(1)(c) deserves to be upheld and sustained. Accordingly, ground no. 1 of the appeal is dismissed and not allowed. Accordingly, ground no. 1 of the appeal is dismissed and not allowed. Accordingly, ground no. 1 of the appeal is dismissed and not allowed.” 4. Before us, referring to the regular grounds, the Ld. counsel for Before us, referring

R J CORPORATION,MUMBAI vs. INCOME TAX OFFICER, 42(1)(4), MUMBAI, MUMBAI

In the result, both the appeals of the assessee are allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

reassessment orders and has not contested the same before the Ld. CIT(A) in quantum proceedings. It was contended that once the assessee has accepted the addition, it necessarily follows that the income was concealed and therefore penalty under section 271(1

R J CORPORATION,MUMBAI vs. INCOME TAX OFFICER, 42(1)(4), MUMBAI, MUMBAI

In the result, both the appeals of the assessee are allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

reassessment orders and has not contested the same before the Ld. CIT(A) in quantum proceedings. It was contended that once the assessee has accepted the addition, it necessarily follows that the income was concealed and therefore penalty under section 271(1

M/S MUMBADEVI VEYHICLES,MUMBAI vs. ITO WARD 41(4)(2), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

reassessment was completed under section 143(3) read with section 147 determining the total income at Rs. 40,50,371/-, being the same income declared by the assessee in response to notice under section 148. No addition over and above the returned income ultimately survived in the assessment order. 22. The Assessing Officer levied penalty under section 271(1

ACIT-3(4), MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

section 271(1)(iii) may be imposed, it has to be proved that the assessee consciously made the concealment or furnished inaccurate particulars of his income. Where the additions made in the assessment order, on the basis of which penalty for concealment was levied, are deleted, there remains no basis at all for levying the penalty for concealment and therefore

ASST. COMMISSIONER OF INCOME TAX 8(2)(1), MUMBAI, MUMBAI vs. PIRAMAL ENTERPRISES LIMITED, MUMBAI

In the result, the cross-objection of the assessee is allowed\nwhereas appeal of the Revenue is dismissed

271(1)(c) dated\n27.12.2007 of the Act issued was defective as particular limb i.e.\nconcealment of income or furnishing of inaccurate particulars of the\nincome was not stricken off by the Assessing Officer while issuing\nnotice for initiation of penalty, relying on the decision of the\nHon'ble Bombay High Court in the case of Mohd. Farhan Shaikh

RELIANCE INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX -CIRCLE 3(4) , MUMBAI

In the result, the appeal of the Revenue is dismissed whereas\nthe appeal of the assessee is allowed

271(1)(c) inherently\ncarried with it the element of mens rea. Therefore, the mere fact\nthat some figure or some particulars have been disclosed by\nitself, even if takes out the case from the purview of non-\ndisclosure, it cannot by itself take out the case from the purview\nof furnishing inaccurate particulars. More omission from the\nreturn

PANASONIC LIFE SOLUTIONS INDIA PVT LTD,THANE vs. ASST CIT CC 7(2), MUMBAI

In the result, Appeal of assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Panasonic Life Solutions India Asst. Commissioner Of Private Limited Income-Tax (Formerly Known As Anchor Central Circle 7(2) Electricals Private Limited) 3Rd Floor, B Wing, 655, 6Th Floor, Aaykar Bhavan Vs. I – Think Techno Campus, M.K. Road, Pokhran Road No.2, Thane Mumbai-400 020 (West) (Appellant) (Respondent) Pan No. Aaeca2190C Assessee By : Shri M.P. Lohia Shri Nikhil Tiwari, Ar Revenue By : Shri Manoj Kumar, Cit Dr Date Of Hearing: 08-12-2023 Date Of Pronouncement : 19.12.2023

1. erred in computing the total income at INR 142,78,72,790 and raising a demand of INR 13,96,46,300 Time barring and validity of the order of the TPO and the AO 2. erred in holding that the order of the assessment order dated 30 November 2018 was not time barred in terms of the provisions