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ACIT, Central Circle 2(3), Pune Vs. Mantra Properties

Case No: ITA No.2116/PUN/2024
Court: Income Tax Appellate Tribunal, Pune Bench 'B'
Date: 23 Sep 2026

Parties Involved

appellantACIT, Central Circle 2(3), Pune
respondentMantra Properties

Facts Summary

The assessee, Mantra Properties, engaged in real estate development and construction, filed its return of income on 30.10.2017 declaring total income of Rs.27,66,64,920/-. The return was revised on 30.10.2018 declaring total income of Rs.16,76,37,960/-. A search and seizure action was conducted on 01.08.2017, revealing that the assessee had taken a cash loan of Rs.1,90,00,000/- from various parties through a finance broker, Shri Sachin Nahar. The case was reopened, and a notice was issued under section 148 of the Income Tax Act, 1961. The Assessing Officer levied a penalty of Rs.1,90,00,000/- under section 271D of the Act, which was later deleted by the Commissioner of Income Tax (Appeals). The Revenue appealed against this order.…

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the penalty levied by the Assessing Officer under section 271D of the Act was justified.
  • 2. Whether the Commissioner of Income Tax (Appeals) was justified in deleting the penalty.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

2 precedents cited in this judgement.

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