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Manishkumar Ramlakhan Agrawal vs. Income Tax Officer

Case No: ITA No. 920/Ahd/2025
Court: Income Tax Appellate Tribunal, Ahmedabad
Date: 8/25/2025

Parties Involved

appellantManishkumar Ramlakhan Agrawal
respondentIncome Tax Officer, Ward-6(1)(1), Ahmedabad

Facts Summary

The assessee, Manishkumar Ramlakhan Agrawal, is an individual serving as Executive Director in Gopinath Enterprise Private Limited. He filed his return of income for the Assessment Year 2018-19 declaring a total income of ₹31,34,370/-. The assessee included exemption from Long-Term Capital Gains of ₹7,85,654/- and Short-Term Capital Gains of ₹6,01,979/-. A Search and Seizure operation under section 132 of the Act was conducted on the Kushal Group of Ahmedabad, which was found to be involved in price rigging and issuing bogus accommodation entries. The Assessing Officer initiated re-assessment proceedings against the assessee, noting that he was a beneficiary of these transactions involving suspicious entries amounting to ₹14,85,833/-. The assessee failed to respond to two crucial notices issued under sections 143(2) and 142(1) of the Act, leading to penalty proceedings under section 272A(1)(d) of the Act.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the penalty imposed under section 271A(1)(d) was justified?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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