PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. Since, the addition was upheld by invoking\n\n11\n\ndeemed provision, penalty cannot be levied. The assessee has further stated that\nthe assessment proceeding and penalty proceedings are distinct. In the\nassessment proceedings, the additions may be good but not for penalty. The\nassessee has relied on the various judgements. However, ld CIT(A) rejected the\nabove contention

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. Since, the addition was upheld by invoking\n11\nH\n==End of OCR for page 11==\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\ndeemed provision, penalty cannot be levied. The assessee has further stated that\nthe assessment proceeding and penalty proceedings are distinct. In the\nassessment proceedings, the additions

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. Since, the addition was upheld by invoking\n11\nH\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\ndeemed provision, penalty cannot be levied. The assessee has further stated that\nthe assessment proceeding and penalty proceedings are distinct. In the\nassessment proceedings, the additions may be good but not for penalty. The\nassessee

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. Since, the addition was upheld by invoking\n11\ndeemed provision, penalty cannot be levied. The assessee has further stated that\nthe assessment proceeding and penalty proceedings are distinct. In the\nassessment proceedings, the additions may be good but not for penalty. The\nassessee has relied on the various judgements. However, ld CIT(A) rejected the\nabove contention

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

TDS. Since, the addition was upheld by invoking\n11\nH\n==End of OCR for page 11==\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\ndeemed provision, penalty cannot be levied. The assessee has further stated that\nthe assessment proceeding and penalty proceedings are distinct. In the\nassessment proceedings, the additions

M/S SHREEJI CONSTRUCTION CO.,,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2(1) (1), RAJKOT

In the result, the case is being restored to the file of the Ld

section 147 of the Act for the reason that the assessee had debited interest expense of ₹ 8,06,835/- and the total outstanding amount of loan was ₹ 24,45,805/-, of which an amount of ₹ 24,26,402/- (about 99%) was taken from non-banking financial company Kotak Mahindra Captive Loan. The Ld. Assessing Officer noted that TDS