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

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 submitted that

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

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 submitted that

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

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 submitted that

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

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 submitted that

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

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 submitted that

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

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

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)

147. However, this will not grant the appellant immunity from imposition of penalty u/s 271F. As per section 3 of Vivad Se Vishwas Act, 2020, the declarant would be provided immunity only for penalty levied on disputed tax, in case he opts I.T.A No. 271

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)

147. However, this will not grant the appellant immunity from imposition of penalty u/s 271F. As per section 3 of Vivad Se Vishwas Act, 2020, the declarant would be provided immunity only for penalty levied on disputed tax, in case he opts I.T.A No. 271

M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

147 read with section 143(3) of the Act in the given facts and circumstances. 14. Coming to the 2nd fold of contention of the learned AR that the assessment framed under section 153C read with section 143(3) of the Act is bad in law and therefore no penalty proceedings can be initiated under section 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)

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)

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)

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)

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)

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)

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)

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)

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)

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

147 read with\nsection 143(3) read with section 144B of the Income Tax Act, 1961. The penalty\nproceedings u/s 271