CIT v. Manjunatha Cotton & Ginning Factory

359 ITR 565High Court2013#6 most cited

What is CIT v. Manjunatha Cotton & Ginning Factory authority for?

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

2,585

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. Manjunatha Cotton & Ginning Factory · section 271(1)(c) · section 274 · penalty notice invalid · non-specification of limb · concealment of income · furnishing inaccurate particulars · bad in law notice · vitiated penalty proceedings · levy of penalty

Also reported as

35 Taxmann.com 250218 Taxmann 423263 CTR 153

Sections most often in play

Section 271(1)(c)Section 274Section 143(3)Section 153ASection 270ASection 139(1)Section 250Section 271AAB

Issues it is cited on

furnishing inaccurate particulars of incomesection 274furnishing inaccurate particularsconcealment of incomepenalty under section 271(1)(c)penalty u/s 271(1)(c)section 271(1)levy of penaltynon-application of mindsection 271section 271(1)(c)section 27

Judgments citing CIT v. Manjunatha Cotton & Ginning Factory

SUBBALAKSHMI KURADA ,BANGALORE vs. DEPUTY COMMISSONER OF INCOME TAX, CIRCLE-3(1)(2) , BANGALORE

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

ITA 1913/BANG/2025[2016-17]Status: DisposedITAT Bangalore15 Apr 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2016-17

For Respondent: Shri V. Narendra Sharma
Section 142Section 143(2)Section 271Section 274Section 54

…concealment of income nor furnishing of any inaccurate particulars of income. Even on this score also, the penalty could not be imposed u/s. 271(1)(c) of the Act. We have also considered the judgment of the Hon’ble Jurisdictional High Court reported in (2013) 359 ITR 565 (Karnataka) in the case of CIT vs. Manjunatha Cotton Ginning Factory which was relied on by the assessee. In the said judgment, it was held that the acceptance of the assessee for the addition is not a proof of concealment of income. We have also perused the judgment of the Hon’ble Supreme Court reported in 322 ITR 158 in the case 8. We have als…

ZF STEERING GEAR (INDIA) LIMITED,PUNE vs. DCIT CENTRAL CIRCLE 15, DELHI

In the result, the appeal of the assessee is allowed in very terms

ITA 4807/DEL/2025[2014-15]Status: DisposedITAT Delhi27 Mar 2026AY 2014-15

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2014-15 Vs M/S Zf Sterling Gear Dcit Central Circle-15, (India) Limited, New Delhi Gat 1242 1244 Vadhu Room No. 245, Dgit Budruk Takuka Shirur (Systems) Ara Koregaon Bhima, Pune, Centre, Ground Maharashtara Floor E-2 (Pan: Aaacz0549G) Jhandewalan Extension, New Delhi (Appellant) (Respondent)

Section 271(1)Section 271(1)(c)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SH. M. BALAGANESH, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2014-15 Vs M/s ZF STERLING GEAR DCIT Central Circle-15, (INDIA) LIMITED, NEW DELHI GAT 1242 1244 VADHU ROOM NO. 245, DGIT BUDRUK TAKUKA SHIRUR (SYSTEMS) ARA KOREGAON BHIMA, PUNE, CENTRE, GROUND MAHARASHTARA FLOOR E-2 (PAN: AAACZ0549G) JHANDEWALAN EXTENSION, NEW DELHI (APPELLANT) (RESPONDENT) Appellant by Shri Shivam Garg, Adv. & Shri Mihir Kaushik, Adv. Respondent by Shri Om Prakash, Sr. DR. Date of hearing: 12/03/2026 Date of Pronouncement: 27…

DAZZLER CONFECTIONERY COMPANY PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 3(1)(1, MUMBAI

In the result, the Assessee’s Appeal is allowed

ITA 8411/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Mar 2026AY 2013-14

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar

For Appellant: Mr. Rahul Sarda, Ld. ARFor Respondent: Shri Annavaram Kosuri, SR AR
Section 250Section 271(1)(c)Section 274Section 35D

…oncealment of particulars of income or furnishing of inaccurate particulars of income in the facts of the present case, penalty proceedings could not have been initiated. 15. The Hon’ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar), has also dealt with identical notice and held as under: 7.2. The Hon'ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar) observed that the levy of penalty has to be clear as to the limb under which it is being levied. As per Hon'ble High Court, where the Assessing Officer proposed to invoke first…

SANJAY JAIN,SAHARANPUR vs. INCOME TAX OFFICER, WARD-3(3)(1),, SAHARANPUR

In the result, the appeal of the assessee is allowed

ITA 6650/DEL/2025[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2013-14 Vs Sanjay Jain, Ito, Ward-3(3)(1), 39, Mission Compound, Sahranpur-247001 Saharanpur-247001 Uttar Pradesh [Pan: Ackpj3369F) (Appellant) (Respondent)

Section 145(3)Section 271(1)Section 271(1)(c)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER Assessment Year: 2013-14 Vs SANJAY JAIN, ITO, WARD-3(3)(1), 39, MISSION COMPOUND, SAHRANPUR-247001 SAHARANPUR-247001 UTTAR PRADESH [PAN: ACKPJ3369F) (APPELLANT) (RESPONDENT) Appellants by Shri Ankit Gupta, Adv. Respondent by Shri Rajesh Kumar Dhanesta, Sr. DR Date of hearing: 25/02/2026 Date of Pronouncement: 13/03/2026 ORDER PER SUDHIR KUMAR, JM: This appeal by the assessee is directed against the order of Ld. National Faceless Appeal Centre (NFAC), Delhi…

AMBER CORPORATION,KALYAN vs. ITO WARD 3(1), KALYAN, KALYAN, THANE

In the result the Assessee’s Appeal is allowed

ITA 8373/MUM/2025[2010-2011]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-2011

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11

For Appellant: Shri. Hitesh ShahFor Respondent: Shri. Surendra Mohan (SR. DR.)
Section 250Section 271Section 271(1)(c)Section 274

…oncealment of particulars of income or furnishing of inaccurate particulars of income in the facts of the present case, penalty proceedings could not have been initiated. 15. The Hon’ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar), has also dealt with identical notice and held as under: 7.2. The Hon'ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar) observed that the levy of penalty has to be clear as to the limb under which it is being levied. As per Hon'ble High Court, where the Assessing Officer proposed to invoke first…

M/S.ALLIED DIGITAL SERVICES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(3), MUMBAI, MUMBAI

In the result the Assessee‟s Appeal is allowed

ITA 8147/MUM/2025[2010-11]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11 M/S. Allied Digital Services Deputy Commissioner Of Limited, Income Tax, Central 808, 8Th Floor, Mafatlal Centre, Circile 1(3), 905,9Th Floor, Nariman Point, Vs. Mumbai – 400021. Old Cgo Building, Pan – Aaaca5509K Pratishtha Bhavan, M.K. Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Ms. Vinita Shah, Ld. A.R. Revenue By : Shri Surendra Mohan, Sr. D.R. Date Of Hearing : 12.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short „The Act‟) For The A.Y. 20101-11. 2. In The Instant Case, The Ao Vide Assessment Order Dated 28.03.2013 Under Section 143 (3) R.W.S. 153(A) Of The Act Has Made The Additions Of Rs.5,35,91,882/- & Rs.1,25,66,049/- On Account Of Disallowances Under Section 69C Of The Act & Section 2 M/S. Allied Digital Services Limited

For Appellant: Ms. Vinita Shah, Ld. A.RFor Respondent: Shri Surendra Mohan, Sr. D.R
Section 143Section 2Section 250Section 271(1)(c)Section 274Section 69C

…oncealment of particulars of income or furnishing of inaccurate particulars of income in the facts of the present case, penalty proceedings could not have been initiated. 15. The Hon’ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar), has also dealt with identical notice and held as under: 7.2. The Hon'ble Karnataka High Court in the case of Manjunatha Cotton & Ginning Factory, 359 ITR 565 (Kar) observed that the levy of penalty has to be clear as to the limb under which it is being levied. As per Hon'ble High Court, where the Assessing Officer proposed to invoke first…

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 223/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

…ibunal dated 05/01/2026 in ITA No. 235 & 266/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was M/s CCL Vs DCIT & 1 Anr. initiated was not…

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 220/RAN/2024[2012-13]Status: DisposedITAT Ranchi20 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 32

…n ITA No. 170 & 178/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. M/s CCL Vs DCIT & 1 Anr. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 218/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Feb 2026AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274

…n ITA No. 169 & 177/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. M/s CCL Vs DCIT & 1 Anr. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LTD, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 217/RAN/2024[2010-11]Status: DisposedITAT Ranchi20 Feb 2026AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

…ibunal dated 05/01/2026 in ITA No. 168 & 176/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was M/s CCL Vs DCIT & 1 Anr. initiated was not…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 213/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

…ibunal dated 05/01/2026 in ITA No. 235 & 266/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was M/s CCL Vs DCIT & 1 Anr. initiated was not…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 212/RAN/2024[2012-13]Status: DisposedITAT Ranchi20 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 32

…n ITA No. 170 & 178/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. M/s CCL Vs DCIT & 1 Anr. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 211/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Feb 2026AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274

…n ITA No. 169 & 177/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. M/s CCL Vs DCIT & 1 Anr. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue

ITA 210/RAN/2024[2010-11]Status: DisposedITAT Ranchi20 Feb 2026AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 271Section 271(1)(c)Section 274Section 40

…ibunal dated 05/01/2026 in ITA No. 168 & 176/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 209/RAN/2024[2009-10]Status: DisposedITAT Ranchi20 Feb 2026AY 2009-10

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

Section 271Section 271(1)(c)Section 274Section 40

…1 Anr. dated 05/01/2026 in ITA No. 167 & 175/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed

ITA 208/RAN/2024[2008-09]Status: DisposedITAT Ranchi20 Feb 2026AY 2008-09

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 14ASection 2Section 271Section 271(1)(c)

…ibunal dated 05/01/2026 in ITA No. 166 & 174/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 7. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

M/S. CENTRAL COALFIELDS LTD.,,RANCHI vs. DCIT CIRCLE-1, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 207/RAN/2024[2006-07]Status: DisposedITAT Ranchi20 Feb 2026AY 2006-07

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

Section 271Section 271(1)(c)Section 274

…ibunal dated 05/01/2026 in ITA No. 164 & 172/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 206/RAN/2024[2009-10]Status: DisposedITAT Ranchi20 Feb 2026AY 2009-10

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

Section 271Section 271(1)(c)Section 274Section 40

…1 Anr. dated 05/01/2026 in ITA No. 167 & 175/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

DCIT,CIRCLE-1RANCHI, RANCHI vs. CENTRAL COALFIELD LTD, RANCHI

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 163/RAN/2024[2006-07]Status: DisposedITAT Ranchi20 Feb 2026AY 2006-07

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee M/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue

Section 271Section 271(1)(c)Section 274

…ibunal dated 05/01/2026 in ITA No. 164 & 172/Ran/2017 and as such, the impugned penalty imposed upon the assessee has no legs to stand. 8. That we rely upon the decision of Hon'ble Kartanaka High Court in the case of CIT Vs Manjunatha Cotton & Ginning Factory 359 ITR 565 and the recent decision of Hon'ble Delhi High Court in PR. Commissioner of Income- tax Central -1 vs. Chetan Gupta [2025] 181 taxmann.com 946 (Delhi)[15- 12-2025] to submit that the notice issued U/s 274 r.w.s 271(1)(c) was an invalid notice since the specific fault for which the penalty proceedings was initiated was not rightly marked and as suc…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, COIMBATORE, COIMBATORE vs. SRI MAHESWARY GRANITES (P) LTD, COIMBATORE

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

ITA 3054/CHNY/2025[2015]Status: DisposedITAT Chennai20 Feb 2026

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 3054/Chny/2025 िनधा"रण वष"/Assessment Year:2015-16 The Asst. Commissioner Of Sri Maheswary Granites (P) Income Tax, Vs. Ltd., Central Circle – 2, Old No.115, New No.84, Coimbatore Bashyakarlu Road West, R.S.Puram, Coimbatore Pan: Aafcs 9118K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. V. Aswathy, Jcit ""यथ" क" ओर से/Respondent By : Shri K.M.C.R. Mohan, Advocate सुनवाई क" तारीख/Date Of Hearing : 19.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

For Appellant: Ms. V. Aswathy, JCITFor Respondent: Shri K.M.C.R. Mohan, Advocate
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 274

…arned Commissioner of Income Tax (Appeals) is erroneous on facts and in law. 2. The Ld.CIT(A) erred in deleting Rs.69,71,783/- levied as penalty u/s 271AAB(1) (c). 3. The Ld.CIT(A) erred in relying on the decision of Manjunatha Cotton & Ginning Factory [2013] 359 ITR 565/218 Taxman 423/35 taxmann.com.250 & Commissioner of Income-tax v. SSA'S Emerald Meadows [2016] 73 taxmann.coт 248 (SC) to render relief to the assessee without taking cognizance of the decision of the Hon'ble Supreme Court of India in Gangotri Textiles Ltd. v. Deputy Commissioner of Income-tax [2022]137 taxmann.com 198 (SC) wherein it has dismiss…

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