ASHOK VIJAYKUMAR KOTECHA,,JALGAON vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

penalty u/s 271 (1)(c) . [C] General: • The appellant reserve rights to add alter or delete any portion of this appeal before its conclusion. • This appeal is filed in time and may please be allowed in full. • A Detailed paper book along with case laws will be submitted at the time of hearing:.” 5. Briefly, the facts of the case

ASHOK VIJAYKUMAR KOTECHA,,JALGAON vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

penalty u/s 271 (1)(c) . [C] General: • The appellant reserve rights to add alter or delete any portion of this appeal before its conclusion. • This appeal is filed in time and may please be allowed in full. • A Detailed paper book along with case laws will be submitted at the time of hearing:.” 5. Briefly, the facts of the case

MARUTI N. NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI N. NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI NIVRUTTI NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI NIVRUTTI NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI NIVRUTTI NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI N. NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI N. NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

MARUTI N. NAVALE,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of the assessee in WTA No

Bench: Shri D. Karunakara Rao, Am & Shri Partha Sarathi Chaudhury, Jm Sl.

Penalty u/s 271(1)(c) is separately initiated.” 16. The CIT(A), as per discussion given in para 3.14 and 3.15 of the order of the CIT(A), confirmed the action of the Assessing Officer. For the sake of completeness, the said para 3.14 and 3.15 of the order of the CIT(A) are extracted hereunder :- “3.14 In this regard

SHRI MANOJ MADANLAL CHHAJED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1)PUNE, PUNE

In the result, the appeal filed by the assessee in ITA

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / It(Ss)A Nos.91 To 96/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 To 2017-18 Shri Manoj Madanlal Vs. Acit, Central Circle- Chhajed, 1(1), Pune. 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / It(Ss)A Nos.97 & 98/Pun/2022 िनधा"रण वष" / Assessment Years : 2012-13 & 2015-16 Acit, Circle-1(1), Pune. Vs. Shri Manoj Madanlal Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent आयकर अपील सं. / Ita No.725/Pun/2022 िनधा"रण वष" / Assessment Year: 2018-19 Shri Manoj Madanlal Vs. Acit, Circle-1(1), Pune. Chhajed, 601, A-8 Building, Karishma Housing Society, Near Sangam Press, Kothrud, Pune- 411029. Pan : Aalpc4991M Appellant Respondent

penalty provisions may be initiated.” It is well settled position in law that admission has to be construed as a whole, for the purpose of its evaluation. The Department cannot adopt “pick and choose” approach, by ignoring that part of the statement which is against the Departmental interests and adopting other part of the statement which suits the Departmental interests

GIRISH B. CHAUDHARI, L/O. OF LATE SHRI BHAGWAT N CHAUDHARI,,JALGAON vs. INCOME-TAX OFFICER,, NASHIK

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteit(Ssa)A No.80/Pun/2017 (Assessment Year:2009-10) Smt. Mahesh Chaudhari The Income Tax Officer 11, Swed Bindu, Shanti Nagar (Central - 1) Vs. Yawat Road, Bhusawal Nashik Jalgaon 425201 Pan –Adkpc7175P Appellant Respondent Shri Girish Bhagwat Chaudhari The Income Tax Officer (Lh Of Late Bhagwat N . Chaudhary) (Central - 1) 11, Swed Bindu, Shanti Nagar Vs. Nashik Yawat Road, Bhusawal Jalgaon 425201 Pan –Aalpc0512G Appellant Respondent

Penalty proceedings u/s, 271(1)(c) of the Act are initiated separately. 49.1 During the course of appellate proceeding, the appellant made the following submission: 6] Ground No.5: Addition of Rs. 7,25,00,000/- towards unexplained investment in land 6.l] The Ld. A.O. has discussed this issue in para 9 of the asst. order. According

ASSISTANT COMMISSIONER OF INCOME-TAX,, KOLHAPUR vs. VIJAYKUMAR RAJARAM SHAH,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,,KOLHAPUR vs. ASSISTANT COMMISISONER OF INCOME-TAX,,

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B

ASSISTANT COMMISSIONER OF INCOME-TAX vs. LAXMI CIVIL ENGINEERING SERVICES PVT. LTD.,, KOLHAPUR

In the result, the appeal of the Revenue in ITA No

Bench: Shri D. Karunakara Rao, Am & Shri S. S. Viswanethra Ravi, Jm Sl.

section 132B of the Act, case laws on the issue and dismissed the appeal filed by the Revenue by observing as under:- “7. We find that the subsequent action of Learned AO in revoking the credit given for seized cash towards existing tax liability under proceedings u/s 154 of the Act is illegal. The provisions of section 132B