JILA SAHAKARI KENDRIYA BANK MARYADIT BHIND,BHIND vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -1, GWALIOR

ITA 193/AGR/2026Status: DisposedITAT Agra22 June 2026AY 2009-109 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee made the claim on a bona fide basis with complete disclosure, and an incorrect claim does not amount to furnishing inaccurate particulars. Therefore, the penalty cannot be imposed.

What were the facts?

The assessee, a cooperative bank, claimed deductions for provisions for doubtful debts and penal interest. The Assessing Officer made disallowances, leading to a penalty under Section 271(1)(c) for furnishing inaccurate particulars. The assessee argued that the disallowances were due to calculation errors and not intentional concealment.

What were the issues?

Whether a penalty under Section 271(1)(c) is leviable when a deduction is disallowed due to a calculation error or difference in interpretation, despite full disclosure.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 274,Section 36(1)(viia)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA BENCH “DB”, NEWDELHI

For Appellant: Shri Neeraj Jain, CA
For Respondent: Shri Harsh Siddharth Gautam, Sr. DR
Hearing: 22.04.2026

PER S. RIFAUR RAHMAN, AM :

1.

This appeal is filed by the assessee against the order of the Ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘ld. CIT(A)] dated 02.07.2025 for the Assessment Year 2009-10. 2. At the time of hearing, ld. AR of the assessee brought to our notice the facts of the case and his submissions are as under.

2

3.

Ld. AR submitted that the present appeal is in respect of penalty of Rs.12,66,520/- under Section 274 read with Section 271(1)(c) of Income-tax Act, 1961 (for short ‘the Act’) for furnishing inaccurate particulars of income thereby concealed income of financial year 2008-09 relevant to assessment

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 271(1)(c)

All 25,141 judgments and leading authorities on Section 271(1)(c) →

Recent GST High Court judgments

Search GST case law →