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

143(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

143(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,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

143(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 ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

143(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

143(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

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961. 7. That, the Ld. CIT(A) has wrongly confirmed the interest charged u/s 234A/B/C of the I. T. Act, 1961. 8. That, the findings of the Ld. CIT(A) are not justified and are bad-in-law.” 3. First, we shall take ground No. 1 and 2, above, raised

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

143(3) r.w.s. 147 of the Act completed on 21.12.2018, and determined taxable income of Rs.92.77.720/-The said order was completed by the then assessing officer, a valuation report of AVO will be finalized, the actual 1. TCG payable. The said valuation report have 1on 30/05/2019. While finalizing the order, the assessing officer also had initiated penalty proceedings u/s 271

SHREENATHJI DEVLOPERS,RAJKOT vs. THE ITO, WARD-2 (1) (1), RAJKOT, RAJKOT

In the result, all the five appeals filed by the assessee are hereby allowed

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

u/s. 144 assessment order is deleted by the Ld. CIT(A). Thus, the grievance made out by the assessee is found to be genuine and reasonable. In the above circumstances the levy of penalty under Section 271(1)(b) in our considered opinion is unwarranted. For better understanding Section 271(1)(b) and 273B are extracted below: “271

SHREENATHJI DEVLOPERS,RAJKOT vs. THE ITO, WARD-2 (1) (1), RAJKOT, RAJKOT

In the result, all the five appeals filed by the assessee are hereby allowed

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

u/s. 144 assessment order is deleted by the Ld. CIT(A). Thus, the grievance made out by the assessee is found to be genuine and reasonable. In the above circumstances the levy of penalty under Section 271(1)(b) in our considered opinion is unwarranted. For better understanding Section 271(1)(b) and 273B are extracted below: “271

SHREENATHJI DEVLOPERS,RAJKOT vs. THE ITO, WARD-2 (1) (1), RAJKOT, RAJKOT

In the result, all the five appeals filed by the assessee are hereby allowed

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

u/s. 144 assessment order is deleted by the Ld. CIT(A). Thus, the grievance made out by the assessee is found to be genuine and reasonable. In the above circumstances the levy of penalty under Section 271(1)(b) in our considered opinion is unwarranted. For better understanding Section 271(1)(b) and 273B are extracted below: “271

SHREENATHJI DEVLOPERS,RAJKOT vs. THE ITO, WARD-2 (1) (1), RAJKOT, RAJKOT

In the result, all the five appeals filed by the assessee are hereby allowed

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

u/s. 144 assessment order is deleted by the Ld. CIT(A). Thus, the grievance made out by the assessee is found to be genuine and reasonable. In the above circumstances the levy of penalty under Section 271(1)(b) in our considered opinion is unwarranted. For better understanding Section 271(1)(b) and 273B are extracted below: “271

SHREENATHJI DEVLOPERS,RAJKOT vs. THE ITO, WARD-2 (1) (1), RAJKOT, RAJKOT

In the result, all the five appeals filed by the assessee are hereby allowed

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

u/s. 144 assessment order is deleted by the Ld. CIT(A). Thus, the grievance made out by the assessee is found to be genuine and reasonable. In the above circumstances the levy of penalty under Section 271(1)(b) in our considered opinion is unwarranted. For better understanding Section 271(1)(b) and 273B are extracted below: “271

SMT. BIJAL DARSHITBHAI PUJARA,,RAJKOT vs. THE DY. COMMR. OF INCOME TAX, CIRCLE-1 (1),, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

section u/s 271(1)(c) of the Act, the Ld. CIT(Appeals) upheld the penalty order with the following observations: “The notice u/s 143(2

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

2)(1) and its income was taxable at the rate of 20 per cent and initiated reassessment and imposed penalty under section 271(1)(c). The Tribunal after considering the facts, deleted the penalty and observed that since there is no change in the income declared and income assessed by the Assessing Officer, it cannot be said that there were

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)

2 percent of the bank credits was not accepted by the assessing officer and the same was taken as NIL for computation purpose. 7. The assessing officer, then framed the assessment, under section 147 read with section 143(3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271

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)

2 percent of the bank credits was not accepted by the assessing officer and the same was taken as NIL for computation purpose. 7. The assessing officer, then framed the assessment, under section 147 read with section 143(3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271

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)

2 percent of the bank credits was not accepted by the assessing officer and the same was taken as NIL for computation purpose. 7. The assessing officer, then framed the assessment, under section 147 read with section 143(3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271

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)

2 percent of the bank credits was not accepted by the assessing officer and the same was taken as NIL for computation purpose. 7. The assessing officer, then framed the assessment, under section 147 read with section 143(3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271

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)

2 percent of the bank credits was not accepted by the assessing officer and the same was taken as NIL for computation purpose. 7. The assessing officer, then framed the assessment, under section 147 read with section 143(3) read with section 144B of the Income Tax Act, 1961. The penalty proceedings u/s 271