SHRI HARESHBHAI J. FALDU,JUNAGADH vs. THE ACIT, CIRCLE JUNAGADH, JUNAGADH
In the result, the appeal filed by the assessee is allowed
ITA 219/RJT/2022[2013-14]Status: DisposedITAT Rajkot31 Mar 2023AY 2013-14
Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 219/Rjt/2022 िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष"/Asstt. Years: 2013-2014 वष"
For Appellant: Ms Devina Patel, ARFor Respondent: Shri Shramdeep Sinha, C.I.T DR
Section 254Section 271Section 271ASection 274
section 271(1)(c) as held the Hon’ble supreme court in the case of Dharmendra Textile Processers reported in 306 ITR 227 are civil proceeding therefore establishment of willful attempt/mens-rea is not necessary to levy penalty. Further, the income was found during the search, had the search not been carried out, the income could have been concealed. Thus