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

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

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

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

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

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

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

penalty proceeding can be initiated under section 271(1)(c) of the Act based on invalid assessment order. 13.1 The procedure under section 153D provides that where the assessment order u/s 153A(1)(b) or 153B(1)(b) is passed by AO below the rank of JCIT, he has to seek approval from the JCIT. The issue arises whether assessment

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

penalty proceedings u/s 271(1)(c) & 271AA, is totally wrong, unwarranted, unjustified and bad in law. Page 17of 44 ITA No. 286 to 298, 177 & 178/Rjt/2022 & 2024 Classic Network Pvt. Ltd. (Group Case) 3. The learned commissioner of Income tax (appeals) – 11, Ahmedabad erred in confirming the action of the assessing officer in respect of charging the interest u/s.234 A/B/C

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

41,45,054/-/-must_be_treated as unexplained cash credits u/s 68 and added back to the assessee's total income. Penalty u/s 271(1)(C) is initiated on these amounts for concealment of income.\niii) Since the data relating additional creditors was not available on online record and assessee fails to prove the genuineness and creditworthiness of creditors, Addition