ACIT v. S.M. Kanappa

72 ITD 474Income Tax Appellate Tribunal#18221 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 348,615 Indian tax judgments — from 2024 to 2025.

Sections most often in play

Section 139(1)Section 139(5)Section 143(3)Section 147Section 148Section 153ASection 271(1)(c)Section 44AB

Issues it is cited on

section 194ldsection 9(i)(vii)section 270a(2)(a)section 9(i)section 194lsection 270a(6)section 270a(2)service pesection 195(1)section 270a(9)section 195(2)under-reporting of income

Judgments citing ACIT v. S.M. Kanappa

Mr. Chittaranjan Trimbak Gaikwad, Pune vs. The Asst. Commissioner of Income Tax, Circle-4, Pune

In the result, the appeal of the assessee is allowed

ITA 759/PUN/2024[2010-11]Status: DisposedITAT Pune10 Jan 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri B.C. MalakarFor Respondent: Shri Ramnath P. Murkunde
Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 271(1)(c)

…0 ITR 144,CIT Vs Dr. R.C. Gupta & Co. (Raj) 122 ITR 567, Union Engineering Co. Vs CIT (Ker) 122 ITR 719,ITO Vs Leela Mammen (ITAT, Cochin) 63 TTJ 252, CIT Vs P.B. Shah & Co. (Pvt.) Ltd. (Cal) 113 ITR 587,ACIT Vs S.M. Kannappa Automobiles (P) Ltd. (ITAT, Bang) 72 ITD 474. In all cases the gist is like this "Simply because assessee agreed to addition of concealed income after detection thereof and filed return in response to enquiry conducted by department, assessee cannot escape from penalty u/s 271(1)(c)' Moreover, The Supreme court in the case of MAK Data (P) Ltd. Vs Commissioner Of Income Tax 358 ITR 593 has cl…

Ibm Corporation, Bangalore vs. Deputy Commissioner of Income-Tax, International Taxation-Circle-1(2), Bangalore

In the result, all the appeals of the assessees are allowed

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…in) 63 TTJ 252 However, to avoid litigation, once the • CIT vs Dr. R.C. Gupta & Co. assessment proceedings were initiated, (Raj.) 122 ITR 719 the assessee made the tax payment • ACIT vs S.M. Kanappa merely to buy peace. Automobiles (P.) Ltd. (ITAT, Bangalore) 72 ITD 474 • T. Prashanth Reddy vs ACIT [2011] 9 taxmann.com 231 (Hyderabad ITAT) - Further, the CIT(A) concluded that the Assessee accepting that receipts are in nature of FTS, itself indicates that under reporting has undertaken and therefore, penalty is leviable. (Page 20 of the CIT(A) order) - The CIT(A) has contended that the The contention that the ex…

Ibm Corporation, Bangalore vs. Deputy Commissioner of Income Tax, International Taxation, Circle-1(2)(1), Bangalore

In the result, all the appeals of the assessees are allowed

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…in) 63 TTJ 252 However, to avoid litigation, once the • CIT vs Dr. R.C. Gupta & Co. assessment proceedings were initiated, (Raj.) 122 ITR 719 the assessee made the tax payment • ACIT vs S.M. Kanappa merely to buy peace. Automobiles (P.) Ltd. (ITAT, Bangalore) 72 ITD 474 • T. Prashanth Reddy vs ACIT [2011] 9 taxmann.com 231 (Hyderabad ITAT) - Further, the CIT(A) concluded that the Assessee accepting that receipts are in nature of FTS, itself indicates that under reporting has undertaken and therefore, penalty is leviable. (Page 20 of the CIT(A) order) - The CIT(A) has contended that the The contention that the ex…

Ibm United Kingdom Limited, Bangalore vs. Deputy Commissioner of Income-Tax, International Taxation-Circle-1(2), Bangalore

In the result, all the appeals of the assessees are allowed

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…in) 63 TTJ 252 However, to avoid litigation, once the • CIT vs Dr. R.C. Gupta & Co. assessment proceedings were initiated, (Raj.) 122 ITR 719 the assessee made the tax payment • ACIT vs S.M. Kanappa merely to buy peace. Automobiles (P.) Ltd. (ITAT, Bangalore) 72 ITD 474 • T. Prashanth Reddy vs ACIT [2011] 9 taxmann.com 231 (Hyderabad ITAT) - Further, the CIT(A) concluded that the Assessee accepting that receipts are in nature of FTS, itself indicates that under reporting has undertaken and therefore, penalty is leviable. (Page 20 of the CIT(A) order) - The CIT(A) has contended that the The contention that the ex…

Ibm Israel Limited, Bangalore vs. Deputy Commissioner of Income-Tax, International Taxation-Circle-1(2), Bangalore

In the result, all the appeals of the assessees are allowed

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

…in) 63 TTJ 252 However, to avoid litigation, once the • CIT vs Dr. R.C. Gupta & Co. assessment proceedings were initiated, (Raj.) 122 ITR 719 the assessee made the tax payment • ACIT vs S.M. Kanappa merely to buy peace. Automobiles (P.) Ltd. (ITAT, Bangalore) 72 ITD 474 • T. Prashanth Reddy vs ACIT [2011] 9 taxmann.com 231 (Hyderabad ITAT) - Further, the CIT(A) concluded that the Assessee accepting that receipts are in nature of FTS, itself indicates that under reporting has undertaken and therefore, penalty is leviable. (Page 20 of the CIT(A) order) - The CIT(A) has contended that the The contention that the ex…

ACIT v. S.M. Kanappa (72 ITD 474) — Cited in 5 Judgments | BharatTax