66 results for “penalty u/s 271”+ Section 21(5)clear
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In the result, the appeal filed by assessee, in ITA No
Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.280 To 282/Srt/2022 Assessment Years: (2009-10) (Physical Hearing) Pinky Manishkumar Jariwala, Vs. The Ito, 4/1710, Nawabwadi, Begampura, Ward – 2(2)(3), Surat – 395003. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahnpj7591D (Appellant) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 23/08/2023 Date Of Pronouncement 28/08/2023
21. Shri Jagasheth, Ld. Counsel for the assessee, pleaded that the penalty under section 271(1)(c) of the Act to the tune of Rs.12,50,901/- was imposed on the fictitious sale. Since the Assessing Officer has already considered the fictitious sale while making the addition, therefore no penalty can be imposed on the fictitious sale, as the fictitious