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

section 250 of the Income Tax Act, 1961 (“the\nAct\" for short), which in turn arise out of separate penalty orders, passed by the\nAssessing Officer u/s 271(1)(c) and 271AAB(1)(c) of the Act.\n\nThe assessee's appeals in ITA Nos.76 to 80/RJT/2022, relates to penalty\nu/s 271(1)(c) of the Act and appeal

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

section 250 of the Income Tax Act, 1961 (“the\nAct\" for short), which in turn arise out of separate penalty orders, passed by the\nAssessing Officer u/s 271(1)(c) and 271AAB(1)(c) of the Act.\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\n2.\nThe assessee's appeals in ITA Nos.76

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

section 250 of the Income Tax Act, 1961 (“the\nAct\" for short), which in turn arise out of separate penalty orders, passed by the\nAssessing Officer u/s 271(1)(c) and 271AAB(1)(c) of the Act.\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\n2.\nThe assessee's appeals in ITA Nos.76

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

section 250 of the Income Tax Act, 1961 (“the\nAct\" for short), which in turn arise out of separate penalty orders, passed by the\nAssessing Officer u/s 271(1)(c) and 271AAB(1)(c) of the Act.\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj C Lodhiya\n2.\nThe assessee's appeals in ITA Nos.76

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

section 271(1)(c). The Tribunal after considering the facts, deleted the penalty and observed that since there is no change in the income declared and income assessed by the Assessing Officer, it cannot be said that there were any concealment of income. Relevant extract is reproduced as under: "We find that the income of the assessee during re-assessment

SMT. BIJAL DARSHITBHAI PUJARA,,RAJKOT vs. THE DY. COMMR. OF INCOME TAX, CIRCLE-1 (1),, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

51,83,487/- and penalty u/s 271(l)(c) was initiaed. The impugned penalty has been levied with respect to this addition. During penalty proceedings as well as during appellate proceedings the assessee has contended that she was under the impression that the said land was agricultural land and therefore a non capital asset. It was contended that during scrutiny

SHRI KANJIBHAI B. RANGANI,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-5(1), RAJKOT-GUJARAT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

U/s. 271(1)(c) of Rs. 5,51,702/- without considering that there is no adequate time and opportunity although the assessee specifically requested for the same. The penalty needs deletion. 4. The Ld. CIT(A) has erred in not bringing any cogent material justifying levy of penalty. The penalty needs deletion. 5. The Ld. CIT(A) has erred

SMT. ZARNABEN VIBHASHBHAI SHETH,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-5(1), RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

section 274 r.w.s. 271(1)(c) was issued dated 10-02-2012. But the assessee failed to make response to the said notice. 4. The AO in absence of any reply/submission from the assessee held that the assessee has concealed income and furnished inaccurate particular of income and the assessee has nothing to say about the same. Hence

SANJAYKUMAR VALLABHBHAI PAN (HUF),RAJKOT vs. ITO, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.958/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2012-13 Sanjaykumar Vallabhbhai Pan (Huf) The Ito, Ward-2(1)(1) बनाम 703-, Pyramid Tower Rajkot. Bansi Park Vs. Amin Marg Rajkot 360 001. Pan : Aaohs 9548 F (अपीलाथ"/Assessee) (""यथ"/Respondent) :

51,210/-. The case of the assessee, selected for scrutiny under CASS. The assessment was completed u/s 143(3) on 17.03.2015, by making addition of Rs.26,06,199/- on account of unexplained income introduced in the guise of agriculture income. The assessing officer also initiated penalty proceedings u/s 271(1)(c) of the Act, for concealment of income. Aggrieved with

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

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

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. 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

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