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

2. First we take ITA No/305/Rjt/2018 for A.Y. 2012-13 for the purpose of adjudication. The assessee has raised the following ground of appeal: The Commissioner of Income-tax (Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.1,33,002/- u/s.271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground

SHRI HARESHBHAI J. FALDU,JUNAGADH vs. THE ACIT, CIRCLE JUNAGADH, JUNAGADH

In the result, the appeal filed by the assessee is allowed

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"

penalty u/s 271(l)(cJ in respect of undisclosed income referred to in Sec. 271AAA(1) of the Act. Hence, it is prayed that the additional ground being wholly legal in nature can be raised at any stage of proceedings and may kindly be admitted for adjudication in the interest of justice. 3. It was pleaded by the assessee

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

penalty proceedings u/s 271(1)(c) was initiated.” 9. As is evident from the above, on account of search action undertaken on the Mehta Group on 20.03.2012 which covered the assessee and his family, it 20 ACIT Vs. Shri Vicky Balkrishna Mehta AY : 2004-05 was found that they held undisclosed foreign accounts in various foreign banks outside India

M/S. GUPTA GLOBAL EXIM PVT. LTD.,,GANDHIDHAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

The appeal of the assessee is allowed, and appeal of the Assessing

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

2. The assessee has raised the following grounds of appeal: “1. That, the learned CIT(A) has erred in imposing penalty u/s. 271(1)(c) of Rs.6,71,930/- is not justified and should be cancelled.” 3. The only issue raised by the assessee is that the learned CIT (A) erred in imposing the penalty

M/S AJAY SALT & CHEMICALS,,UNA vs. I.T.O., WARD-1(3),, VERAVAL

In the result, the appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No.296/Rjt/2017 "नधा"रण वष"/Asstt. Year: 2006-2007

2. The interconnected issued raised by the assessee is that the learned CIT (A) erred in confirming the penalty of Rs. 1,61,568/- imposed under section 271 (1)(c) of the Act. 3. Briefly stated facts are that, the assessee is a firm and engaged in the business of supply of Lime Stone. During the year under consideration

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

2. On merits, the Learned Commissioner of Income-tax(Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.60,738/- u/s. 271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The assessee vide letter dated

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

2. On merits, the Learned Commissioner of Income-tax(Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.60,738/- u/s. 271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The assessee vide letter dated

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

2. On merits, the Learned Commissioner of Income-tax(Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.60,738/- u/s. 271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The assessee vide letter dated

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

2. On merits, the Learned Commissioner of Income-tax(Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.60,738/- u/s. 271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The assessee vide letter dated

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

2. On merits, the Learned Commissioner of Income-tax(Appeals)-11, Ahmedabad erred in upholding levy of penalty of Rs.60,738/- u/s. 271(1)(c) of the Act. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The assessee vide letter dated

ALIADAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4, , VERAVAL

In the result, appeal of the assessee is dismissed

penalty proceeding u/s. 254 rws 271 (1)( c) of the Act. my kindly be deleted 5. Your Honor's appellant craves leave to add, alter, amend, or withdraw any or more grounds of appeal on or before the hearing of appeal.” ITA No. 473/Rjt/2017 For A.Y. 2013-14 I.T.A Nos. 472, 473 & 474/Rjt/2017

ALIDAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4,, VERAVAL

In the result, appeal of the assessee is dismissed

penalty proceeding u/s. 254 rws 271 (1)( c) of the Act. my kindly be deleted 5. Your Honor's appellant craves leave to add, alter, amend, or withdraw any or more grounds of appeal on or before the hearing of appeal.” ITA No. 473/Rjt/2017 For A.Y. 2013-14 I.T.A Nos. 472, 473 & 474/Rjt/2017

ALIDAR SEVA SAHAKARI MANDLI LTD.,,GIR SOMNATH vs. INCOME TAX OFFICER, WARD-4,, VERAVAL

In the result, appeal of the assessee is dismissed

penalty proceeding u/s. 254 rws 271 (1)( c) of the Act. my kindly be deleted 5. Your Honor's appellant craves leave to add, alter, amend, or withdraw any or more grounds of appeal on or before the hearing of appeal.” ITA No. 473/Rjt/2017 For A.Y. 2013-14 I.T.A Nos. 472, 473 & 474/Rjt/2017

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

271 (1)(c) of the IT Act is initiated for concealing the particulars of income." 3.12.2. Same finding has been given by the A.O. for the other assessment years in all the case of above mentioned appellant. During the appellate proceedings, the appellant filed detailed submission against the additions made. The appellant contended that they are engaged in the business

JITENDRABHAI BHAGVANBHAI DALVADI,SURENDRANAGAR vs. ITO WARD 2, MORBI

In the result, the appeal of the assessee is allowed

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

penalty proceedings u/s 271(1)(c) and 271(1)(b) of the I.T. Act, 1961 Jitendrabhai B Dalvadi 2 4. That, the Ld. CIT(A) has wrongly confirmed levy of interest u/s 234A, 234B & 234C of the Income Tax Act, 1961. 5. That, the findings of the Ld. assessing officer and Ld. CIT(A) are not justified

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

271 (1)(c) of the IT Act is initiated for concealing the particulars of income." 3.12.2. Same finding has been given by the A.O. for the other assessment years in all the case of above mentioned appellant. During the appellate proceedings, the appellant filed detailed submission against the additions made. The appellant contended that they are engaged in the business

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

271 (1)(c) of the IT Act is initiated for concealing the particulars of income." 3.12.2. Same finding has been given by the A.O. for the other assessment years in all the case of above mentioned appellant. During the appellate proceedings, the appellant filed detailed submission against the additions made. The appellant contended that they are engaged in the business

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

271 (1)(c) of the IT Act is initiated for concealing the particulars of income." 3.12.2. Same finding has been given by the A.O. for the other assessment years in all the case of above mentioned appellant. During the appellate proceedings, the appellant filed detailed submission against the additions made. The appellant contended that they are engaged in the business

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

penalty proceedings under Section 271(1) (c) of the Act. 4. Aggrieved, the assessee has filed an appeal before the Ld. CIT (A) only two additional grounds: ITA No.336 /RJT/2023 Kumar Ramesh Sahu vs. ACIT Asst.Year - 2009-10 Ground of appeal No.-3: "Ld. Assessing officer erred in law and facts to issue of notice u/s