ANGEL BROKING LIMITED (FORMERLY KNOWN AS ANGEL COMMODITIES BROKING PRIVATE LIMITED SINCE MERGED WITH ANGEL BROKING PRIVATE LIMITED),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 8(3), MUMBAI

PDF · subscribers
ITA 4803/MUM/2018Status: DisposedITAT Mumbai19 December 2019AY 2009-105 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had already offered a portion of the amount to tax in a subsequent year and that the remaining issue was a matter of reconciliation, not concealment of income. Therefore, penalty under Section 271(1)(c) was not justified.

What were the facts?

The assessee's assessment for AY 2009-10 included disallowances, one of which was for Sundry Collections from Clients. In set-aside proceedings, a portion of this amount remained disallowed as the assessee could not reconcile it.

What were the issues?

Whether penalty under Section 271(1)(c) is leviable for a disallowance that was a matter of reconciliation and where a part was offered to tax in a subsequent year.

Which sections of the Income-tax Act were involved?

Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “A” BENCH, MUMBAI

Before: HON’BLE SHRI VIKAS AWASTHY, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

For Appellant: Shri S. Michael Jerald - Ld. DR

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : अपीलाथ�/ The Appellant 1. ��थ�/ The Respondent 2.

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 →