PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, 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

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, 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,RAKJOT vs. THE ACIT, 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 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) 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

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

271 (1)(C) of the Income Tax Act 1961, the Assessing Officer, has initiated penalty on both limbs, that is, "furnished inaccurate particulars of income as well as concealed particulars of income" 10. However, in the assessment order, the Assessing Officer, vide order dated 21/12/2018, passed u/s 148 read with section 143(3

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)" CIT v. Praveen B. Gada (HUF).- (2011) 244 CTR 463 - Madhya Pradesh HC: DCIT (Intl.Taxn.) vs. M/s.Korea South East Power Co.Ltd. AY : 2011-12 [7] "Section 271(1)(c) of the Income-tax Act, 1961 Penalty For concealment of income-Assessment year 2004-05- Whether in absence of any independent finding by Assessing Officer that assessee concealed his 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)

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)

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 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

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)

3) of the Act. As stated by the assessee during the appellate proceedings, the entire additions made 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

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)

3) of the Act. As stated by the assessee during the appellate proceedings, the entire additions made 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

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)

3) of the Act. As stated by the assessee during the appellate proceedings, the entire additions made 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

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)

3) of the Act. As stated by the assessee during the appellate proceedings, the entire additions made 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

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)

3) of the Act. As stated by the assessee during the appellate proceedings, the entire additions made 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

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

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

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

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