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

3) r.w.s. 147 of the Act, dated 10.07.2017, and\ninitiated penalty proceedings u/s.271AAB of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said addition. Accordingly, the assessing\nofficer had levied Penalty u/s.271AAB(1)(c) of the Act on the confirmed\naddition of Rs.1,80,000/-which was not disclosed. During the penalty\nproceedings, the assessee

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

3) r.w.s. 147 of the Act, dated 10.07.2017, and\ninitiated penalty proceedings u/s.271AAB of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said addition. Accordingly, the assessing\nofficer had levied Penalty u/s.271AAB(1)(c) of the Act on the confirmed\naddition of Rs.1,80,000/-which was not disclosed. During the penalty\nproceedings, the assessee

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

3) r.w.s. 147 of the Act, dated 10.07.2017, and\ninitiated penalty proceedings u/s.271AAB of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said addition. Accordingly, the assessing\nofficer had levied Penalty u/s.271AAB(1)(c) of the Act on the confirmed\naddition of Rs.1,80,000/-which was not disclosed. During the penalty\nproceedings, the assessee

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

3) rw.s. 153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271

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

3) r.w.s. 147 of the Act, dated 10.07.2017, and\ninitiated penalty proceedings u/s.271AAB of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said addition. Accordingly, the assessing\nofficer had levied Penalty u/s.271AAB(1)(c) of the Act on the confirmed\naddition of Rs.1,80,000/-which was not disclosed. During the penalty\nproceedings, the assessee

JETHANAND ATMARAM DHANWANI,ADIPUR vs. ITO WARD - 1, GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 51/Rjt/2025 Assessment Year: (2014-15) (Hybrid Hearing) Jethanand Atmaram Dhanwani Vs. Ito, Ward - 1 Plot No. 368, Wd – 2/B, Adipur – Kutch-370205 "थायीलेखासं./जीआइआरसं.At/Pan/Gir No.: Afvpd8813Q (Appellant) (Respondent) Appellant By : Shri Kalpesh Doshi, Ld. A.R. Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 10/03/2025 Date Of Pronouncement : 04/06/2025

section 271(1)(c) of the Act, in any manner and hence the penalty u/s. 271(1)(c) of the Act, imposed by the assessing officer is deleted. Hence this ground of the assessee is allowed. 13. In the result, appeal filed by the assessee is allowed. Order is pronounced on 04/06/2025 in the open court. (Dr. A.L. SAINI) ACCOUNTANT

THE DCIT, (INTL. TAXN.), RAJKOT vs. M/S. KOREA SOUTH EAST POWER CO. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar(Conducted Through Virtual Court) Assessment Year: 2011-12 The Dcit (Intl. Taxn.) M/S.Korea South East Power Amruta Estate Co.Ltd. Room No.312 Mg Road बनाम/ C/O. P.V. Page & Co., Girnar Cinema 201, Sardar Griha, 198 L.T. Marg Vs. Rajkot Mumbai – 400 002 (Appellant) (Respondent) Pan: Pan : Ahvps 3555Q Assessee By None Revenue By Shri Ashish Kumar Pandey, Sr.Dr Date Of Hearing 25/09/2023 Date Of Pronouncement 15/12/2023

3. We have carefully gone through the order of the Ld.CIT(A) deleting the levy of penalty and we have noted that she deleted the penalty noting that • the only impact of the assessment was rejecting the assessee’s claim of returning presumptive income u/s.44BBB of the Act and treating it as taxable as FTS @ 10% of the gross income

SHRI RAJNIKANT HARGOVINDDAS SANADIA,RAJKOT vs. THE ITO, WARD-2 (3)(5), RAJKOT, RAJKOT

In the result, the appeal filed by the Assessee in ITA No

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 139(1) of the Act, when the total income of the assessee was Rs. 5,13,890/- relating to the Assessment Year 2011-12. Hence Ld. A.O. initiated penalty proceedings u/s. 271F of the Act for non-filing of Return of Income. When a show cause notice was issued for levying penalty u/s. 271F, the assessee replied to keep

SHRI RAJNIKANT HARGOVINDDAS SANADIA,RAJKOT vs. THE ITO, WARD-2 (3)(5), RAJKOT, RAJKOT

In the result, the appeal filed by the Assessee in ITA No

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 139(1) of the Act, when the total income of the assessee was Rs. 5,13,890/- relating to the Assessment Year 2011-12. Hence Ld. A.O. initiated penalty proceedings u/s. 271F of the Act for non-filing of Return of Income. When a show cause notice was issued for levying penalty u/s. 271F, the assessee replied to keep

M/S SHREE RAJMOTI INDS.,,RAJKOT-GUJARAT vs. THE A. C.I.T., CIRCLE-2(1),, RAJKOT-GUJARAT

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

u/s 271 (1) (C). That is clearly no the intendment of the Legislature. 8.1. Following the above Supreme Court Judgment, the Jurisdictional High Court in the case of PCIT Vs. Intas Pharma Ltd. reported in [2022] 138 taxmann.com 474 (Gujarat) held as follows: “Section 271(1)(c), read with section 32, of the Income-tax Act, 1961 Penalty - For concealment

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271(1)(c) of the Income-tax Act, 1961, was initiated for concealment of the particulars of income by the assessing officer. The penalty proceedings u/s 271F of the Income-tax Act, 1961, was initiated for failure to furnish particulars of return of income. Further