CIT v. Ankita Electronics Pvt. Ltd.

379 ITR 50High Court2015#2602 most cited

What is CIT v. Ankita Electronics Pvt. Ltd. authority for?

When the High Court admits a substantial question of law concerning an assessee's claim or alleged default, it indicates the assessee's bona fides, thereby preventing the imposition of penalties under sections 271(1)(c) or 271C. The mere disallowance of a claim or an addition by revenue authorities does not automatically lead to a penalty if the issue is debatable and pending appeal.

45

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2026.

Also referred to as

CIT v. Ankita Electronics Pvt. Ltd. · 379 ITR 50 · Section 271(1)(c) penalty · Section 271C penalty · admission of substantial question of law · bona fides of assessee · debatable claim · disallowance · failure to deduct tax

Sections most often in play

Section 271(1)(c)Section 274Section 143(3)Section 2(19)Section 250Section 271CSection 80PSection 80P(2)

Judgments citing CIT v. Ankita Electronics Pvt. Ltd.

DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION, CIRCLE-2(1) BENGALURU, BENGALURU vs. PALMER INVESTMENT GROUP LIMITED, VIRGIN ISLANDS

In the result, the appeal filed by the revenue is dismissed

ITA 2431/BANG/2024[2014-15]Status: DisposedITAT Bangalore01 Apr 2026AY 2014-15

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.

For Respondent: Shri Percy Pardiwala, Sr. Advocate
Section 143(2)Section 271(1)(c)Section 271CSection 274Section 275

…ntention of the Ld.AR has some force and it also got support from the Division Bench judgements of the Hon’ble Karnataka High Court cited supra. 10. We have also gone through the Division Bench judgments of the Hon’ble Karnataka High Court reported in (2015) 379 ITR 50 in the case of CIT Vs. Ankita Electronics (P.) Ltd. wherein it was held that “the admission of substantial question of law by the High Court leads credence to the bonafide of the assessee and therefore the penalty is not leviable u/s. 271(1)(c) and merely because the claim of the assessee has been rejected by the revenue authorities would not make…

SHREE SHARANAVASACESHWAR CREDIT SOUHARD SAHAKARI NI HALINGALI,HALINGALI vs. INCOME TAX OFFICER, WARD-1, BAGALKOT

In the result, appeal filed by the assessee is allowed

ITA 154/BANG/2025[2016-17]Status: DisposedITAT Bangalore12 Aug 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17 Shree Sharanabasaveshwar Credit Souhard Sahakari Ni Halingali Ito Tq Jamkhandi, Dt Bagalkot Vs. Ward-1 Halingali, Karnataka 587315 Bagalkot Pan No :Aaeas6699C Appellant Respondent Appellant By : Sri Sandeep Chalapathy, A.R. Respondent By : Sri Subramanian S., D.R. Date Of Hearing : 14.05.2025 Date Of Pronouncement : 12.08.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 07.11.2024 Vide Din & Order No. Itba/Nfac/S/250/2024-25/1070176573(1) Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2016-17. 2. The Assessee Has Raised The Following Ground Of Appeal: -

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Sri Subramanian S., D.R
Section 143(3)Section 250Section 271(1)(c)Section 274Section 80PSection 80P(2)Section 80P(2)(a)

…or it has been taxed in the wrong year.” Shree Sharanabasaveshwar Credit Souhard Sahakari Ni Halingali Page 6 of 7 9.2. Further, The Hon’ble High Court of Karnataka in the case of Commissioner of Income Tax vs. Ankita Electronics (P) Ltd. Reported in [2015] 379 ITR 50 (Karnataka) held as under- 8. The assessee in the present case had disclosed all the materials on which it was claiming deduction. The matter as to whether the deduction was to be given or not, was taken up by the revenue authorities and it was held that certain deductions claimed by the assessee were to be disallowed. It is not disputed that the…

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

ITA 906/CHANDI/2019[2008-09]Status: DisposedITAT Chandigarh06 Dec 2022AY 2008-09

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh.Harry Rikhy, AdvocateFor Respondent: Smt. AmanpreetKaur, Sr. DR
Section 133ASection 206Section 206CSection 271C

…It was submitted that in the case of State Bank of India Vs. ADIT as well as Syndicate Bank Vs. ACIT (TDS) (supra), the Coordinate Bangalore Benches have relied upon the decision of the Hon'ble Karnataka High Court in the case of Ankita Electronics Pvt. Ltd 379 ITR 50 (Kar), wherein, it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions. Further, reliance was placed on the decision of ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs…

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,SHIMLA vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

ITA 905/CHANDI/2019[2007-08]Status: DisposedITAT Chandigarh06 Dec 2022AY 2007-08

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh.Harry Rikhy, AdvocateFor Respondent: Smt. AmanpreetKaur, Sr. DR
Section 133ASection 206Section 206CSection 271C

…It was submitted that in the case of State Bank of India Vs. ADIT as well as Syndicate Bank Vs. ACIT (TDS) (supra), the Coordinate Bangalore Benches have relied upon the decision of the Hon'ble Karnataka High Court in the case of Ankita Electronics Pvt. Ltd 379 ITR 50 (Kar), wherein, it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions. Further, reliance was placed on the decision of ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs…

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

ITA 904/CHANDI/2019[2008-09]Status: DisposedITAT Chandigarh06 Dec 2022AY 2008-09

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh.Harry Rikhy, AdvocateFor Respondent: Smt. AmanpreetKaur, Sr. DR
Section 133ASection 206Section 206CSection 271C

…It was submitted that in the case of State Bank of India Vs. ADIT as well as Syndicate Bank Vs. ACIT (TDS) (supra), the Coordinate Bangalore Benches have relied upon the decision of the Hon'ble Karnataka High Court in the case of Ankita Electronics Pvt. Ltd 379 ITR 50 (Kar), wherein, it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions. Further, reliance was placed on the decision of ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs…

THE ASSISTANT EXCISE & TAXATION COMMISSIONER ,NAHAN vs. ADDL. CIT, RANGE, SHIMLA

In the result, all four appeals filed by the assessee are allowed

ITA 903/CHANDI/2019[2007-08]Status: DisposedITAT Chandigarh06 Dec 2022AY 2007-08

Bench: Smt. Diva Singh & Shri Vikram Singh Yadavआयकरअपीलसं./Ita No.903 /Chd/2019 "नधा"रण वष" / Assessment Year :2007-08 The Assistant Excise & बनाम The Additional Cit, Taxation Commissioner, Tds Range, Nahan Shimla "थायीलेखासं./Pan/Tan No: Ptla12468B अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh.Harry Rikhy, AdvocateFor Respondent: Smt. AmanpreetKaur, Sr. DR
Section 133ASection 206Section 206CSection 271C

…It was submitted that in the case of State Bank of India Vs. ADIT as well as Syndicate Bank Vs. ACIT (TDS) (supra), the Coordinate Bangalore Benches have relied upon the decision of the Hon'ble Karnataka High Court in the case of Ankita Electronics Pvt. Ltd 379 ITR 50 (Kar), wherein, it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions. Further, reliance was placed on the decision of ITA Nos. 903 to 905-Chd-2019 - Assistant Excise & Taxation Commissioner Nahan & Othrs…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE- 3, BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 2/BANG/2020[2014-15]Status: DisposedITAT Bangalore09 Nov 2020AY 2014-15

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.H.Muralidhar, CAFor Respondent: Sri.Priyadarshi Mishra, JCIT-DR
Section 10(5)Section 133ASection 192Section 201Section 201(1)Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

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

ITA 404/BANG/2020[2013-14]Status: DisposedITAT Bangalore05 Oct 2020AY 2013-14

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

For Appellant: Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAsFor Respondent: Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru
Section 10Section 10(5)Section 271Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

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

ITA 403/BANG/2020[2012-13]Status: DisposedITAT Bangalore05 Oct 2020AY 2012-13

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

For Appellant: Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAsFor Respondent: Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru
Section 10Section 10(5)Section 271Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

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

ITA 402/BANG/2020[2011-12]Status: DisposedITAT Bangalore05 Oct 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

For Appellant: Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAsFor Respondent: Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru
Section 10Section 10(5)Section 271Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE-3, BANGALORE

In the result, the penalty's levied under section 271C is hereby directed to be deleted

ITA 2378/BANG/2019[2012-13]Status: DisposedITAT Bangalore30 Jun 2020AY 2012-13

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2012 – 13

For Appellant: Shri Muralidhara H, C.AFor Respondent: Shri Manjeet Singh, Addl. CIT
Section 10(5)Section 271C

…ition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. in this regard the learned counsel for the Assessee placed reliance on the decision of the Hon 'b/c Karnataka High Court in the case of ('IT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High court lends credence to the bona fides of the acsessee in his action and hence no penalty can he imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE-3, BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 2524/BANG/2019[2012-13]Status: DisposedITAT Bangalore28 Feb 2020AY 2012-13

Bench: Shri N.V Vasudevan, Vice Presidnet & Shri B.R Baskaranassessment Year : 2012-13

For Appellant: Shri Muralidhara H, C.AFor Respondent: Shri Priyadarshi Misra, JCIT (DR)
Section 10(5)Section 133ASection 201Section 201(1)Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C'. In this regard the learned counsel for the Assessee placed reliance on the decisionvf the Hon'ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona .fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon 'ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE - 3, BANGALORE

In the result appeal filed by assessee stands allowed

ITA 2450/BANG/2019[2012-13]Status: DisposedITAT Bangalore14 Feb 2020AY 2012-13

Bench: Shri. A. K. Garodia & Smt. Beena Pillai

For Appellant: Mr. Shahnawaz Ul Rahman, JCIT – DRFor Respondent: Shri. H. Muralidhar, CA
Section 10(5)Section 133ASection 192Section 201Section 201(1)Section 270Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE - 3, BANGALORE

In the result, the appeals are allowed

ITA 2417/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Feb 2020AY 2013-14

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

For Appellant: Shri H. MuralidharaFor Respondent: Shri Manjeet Singh, Addl.CIT(DR)(ITAT), Bengaluru
Section 10Section 10(5)Section 271

…dition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. ITA Nos. 2413 to 2415/Bang/2019 Page 13 of 15 13. The learned DR relied on the order of CIT(A) and further drew our attention…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE - 3, BANGALORE

In the result, the appeals are allowed

ITA 2414/BANG/2019[2012-13]Status: DisposedITAT Bangalore12 Feb 2020AY 2012-13

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

For Appellant: Shri H. MuralidharaFor Respondent: Shri Manjeet Singh, Addl.CIT(DR)(ITAT), Bengaluru
Section 10Section 10(5)Section 271

…dition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. ITA Nos. 2413 to 2415/Bang/2019 Page 13 of 15 13. The learned DR relied on the order of CIT(A) and further drew our attention…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE- 3, BANGALORE

In the result, the appeals are allowed

ITA 2413/BANG/2019[2011-12]Status: DisposedITAT Bangalore12 Feb 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

For Appellant: Shri H. MuralidharaFor Respondent: Shri Manjeet Singh, Addl.CIT(DR)(ITAT), Bengaluru
Section 10Section 10(5)Section 271

…dition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. ITA Nos. 2413 to 2415/Bang/2019 Page 13 of 15 13. The learned DR relied on the order of CIT(A) and further drew our attention…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE- 3, BANGALORE

In the result, the appeals are allowed

ITA 2416/BANG/2019[2012-13]Status: DisposedITAT Bangalore12 Feb 2020AY 2012-13

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

For Appellant: Shri H. MuralidharaFor Respondent: Shri Manjeet Singh, Addl.CIT(DR)(ITAT), Bengaluru
Section 10Section 10(5)Section 271

…dition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. ITA Nos. 2413 to 2415/Bang/2019 Page 13 of 15 13. The learned DR relied on the order of CIT(A) and further drew our attention…

M/S. STATE BANK OF INDIA,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, TDS RANGE - 3, BANGALORE

In the result, the appeals are allowed

ITA 2415/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Feb 2020AY 2013-14

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

For Appellant: Shri H. MuralidharaFor Respondent: Shri Manjeet Singh, Addl.CIT(DR)(ITAT), Bengaluru
Section 10Section 10(5)Section 271

…dition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. ITA Nos. 2413 to 2415/Bang/2019 Page 13 of 15 13. The learned DR relied on the order of CIT(A) and further drew our attention…

M/S. STATE BANK OF INDIA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- TDS -CIRCLE - 3(1), BANGALORE

In the result, the assessee’s appeals in ITA Nos

ITA 1172/BANG/2019[2012-13]Status: DisposedITAT Bangalore18 Nov 2019AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

For Respondent: Shri M.Vijay Kumar, Add.CIT(DR)
Section 10(5)Section 133ASection 201Section 206Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

M/S. STATE BANK OF INDIA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX- TDS -RANGE - 3, BANGALORE

In the result, the assessee’s appeals in ITA Nos

ITA 1171/BANG/2019[2012-13]Status: DisposedITAT Bangalore18 Nov 2019AY 2012-13

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

For Respondent: Shri M.Vijay Kumar, Add.CIT(DR)
Section 10(5)Section 133ASection 201Section 206Section 271C

…ddition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. In this regard the learned counsel for the Assessee placed reliance on the decision of the Hon’ble Karnataka High Court in the case of CIT v. Ankita Electronics Pvt. Ltd. 379 ITR 50 (Kar) wherein it was held that the admission of substantial question of law by the High Court lends credence to the bona fides of the assessee in his action and hence no penalty can be imposed on such additions/defaults. He also placed reliance on a decision of the Hon’ble ITAT Jaipur Bench in the case of State Bank of India Vs. ACIT (2019) 101 ta…

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