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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

92 & 93/RJV2018, dated 09.10.2018, the following additions were confirmed, on which penalty u/s 271(1)(c) of the Act, was proposed to levy by the assessing officer: (1) Income earned out of credit entries in undisclosed foreign account : Rs.1,04,61,096/- (2) Deemed rent of more than one properties, reflected in the Balance Sheet Rs.1,80,000/- (3) Disallowance

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

92 & 93/RJV2018, dated 09.10.2018, the following additions were confirmed, on which penalty u/s 271(1)(c) of the Act, was proposed to levy by the assessing officer: (1) Income earned out of credit entries in undisclosed foreign account : Rs.1,04,61,096/- (2) Deemed rent of more than one properties, reflected in the Balance Sheet Rs.1,80,000/- (3) Disallowance

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

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

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

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

92 & 93/RJV2018, dated 09.10.2018, the following additions were confirmed, on which penalty u/s 271(1)(c) of the Act, was proposed to levy by the assessing officer: (1) Income earned out of credit entries in undisclosed foreign account : Rs.1,04,61,096/- (2) Deemed rent of more than one properties, reflected in the Balance Sheet Rs.1,80,000/- (3) Disallowance

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)

Penalty proceedings u/s. 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

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

Penalty proceedings u/s. 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

KANTILAL BABULAL SOLANKI,,JUNAGADH vs. THE INCOME TAX OFFICER, WARD-2, JUNAGADH

In the result, the quantum appeal in ITA No

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Penalty order u/s. 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2011-12. I.T.A No. 124/Rjt/2016 & 115/A/2019 A.Y. 2011-12 Page No 2 Kantilal Babulal Solanki Vs. ITO 2. Brief facts of the case is that the assessee is an individual. For the Asst. Year

KANTILAL BABULAL SOLANKI,,JUNAGADH vs. THE INCOME TAX OFFICER, WARD-1(2),, JUNAGADH

In the result, the quantum appeal in ITA No

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Penalty order u/s. 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2011-12. I.T.A No. 124/Rjt/2016 & 115/A/2019 A.Y. 2011-12 Page No 2 Kantilal Babulal Solanki Vs. ITO 2. Brief facts of the case is that the assessee is an individual. For the Asst. Year

THE ACIT, CIRCLE- 1,, RAJKOT-GUJARAT vs. SMT. MANISHABEN N. MASHRU,, RAJKOT-GUJARAT

In the result, appeal of the Revenue in ITA No

Bench: Shri Pramod Kumar & Shri Rajpal Yadavsr.No.

penalty imposed by the Assessing Officer under section 271(1)(c) of the Income Tax Act, 1961 for the Assessment Years 2004-05 and 2005-06. Since in all these appeals/cross- objections, issues and facts are intertwined to each other, we proceed to dispose of all by this common order for the sake of brevity and convenience. 3. Before adverting

SHRI PRASHANT JENTILAL RAMANI,RAJKOT vs. THE ITO 3 (1) (3), RAJKOT, RAJKOT

In the result, these Tax Appeals are also allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 147 r.w.s. 144 and penalty levied u/s. 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the same Assessment Year (A.Y) 2010-11. I.T.A Nos. 152 & 153/Rjt/2023 A.Y. 2010-11 Page No 2 Prashant Jentilal Ramani Vs. ITO 2. The brief facts of the case is that the assessee

SHRI PRASHANT JENTILAL RAMANI,RAJKOT vs. THE ITO 3 (1) (3), RAJKOT, RAJKOT

In the result, these Tax Appeals are also allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 147 r.w.s. 144 and penalty levied u/s. 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the same Assessment Year (A.Y) 2010-11. I.T.A Nos. 152 & 153/Rjt/2023 A.Y. 2010-11 Page No 2 Prashant Jentilal Ramani Vs. ITO 2. The brief facts of the case is that the assessee

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

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

Penalty proceedings u/s. 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

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

Penalty proceedings u/s. 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

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

Penalty proceedings u/s. 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

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

Penalty proceedings u/s. 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

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

Penalty proceedings u/s. 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

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

Penalty proceedings u/s. 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

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

Penalty proceedings u/s. 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

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

Penalty proceedings u/s. 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