CIT v. Raj Trading Co.

217 ITR 208High Court1996#10348 most cited

What is CIT v. Raj Trading Co. authority for?

Furnishing inaccurate particulars of income relates to particulars that have been provided by the assessee, while concealment of income means the income has not been declared at all. The phrase 'inaccurate particulars' is broader and can include inaccuracies that lead to under-declaration or escapement of income.

10

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2014 to 2025.

Also referred to as

CIT v. Raj Trading Co. · 217 ITR 208 · furnishing inaccurate particulars · concealment of income · penalty under section 271(1)(c) · inaccurate particulars vs concealment · definition of inaccurate particulars · section 271 · section 132 · section 143(3)

Sections most often in play

Section 132Section 14Section 143(3)Section 153ASection 271Section 271(1)(c)Section 274Section 292BB

Judgments citing CIT v. Raj Trading Co.

Panjurajan Ganesan, Sivakasi vs. DCIT, CC - 2, Madurai

The appeal of the assessee is allowed

ITA 278/CHNY/2020[2009-10]Status: DisposedITAT Chennai02 Jul 2025AY 2009-10

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकरअपील सं./Ita Nos.278/Chny/2020 Assessment Year: 2009-10 Panjurajan Ganesan Vs. Deputy Commissioner Of Income Tax, No.74A, Velayutham Road, Corporate Circle-2, Sivakasi, Madurai. Tamil Nadu-626 123. [Pan:Abypg3315R] (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. D. Anand, Advocate प्रत्यर्थी की ओर से /Respondent By : Ms. G. Latchana, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 03.07.2025 घोषणा की तारीख /Date Of Pronouncement : 03.07.2025

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. G. Latchana, Addl.CIT
Section 132Section 143(3)Section 271Section 271(1)(c)Section 274

…nd would refer to inaccuracy which would cause under declaration or escapement of income. It may refer to particulars which should have been furnished or were required to be furnished or recorded in the books of account etc. (See CIT v. Raj Trading Co. [1996] 217 ITR 208 (Raj.)). Inaccuracy or wrong furnishing of income would be covered by the said expression, though there are decisions that ad hoc addition per se without other or corroborating circumstances may not reflect “furnished inaccurate particulars”. Lastly, at times and it is fairly common, the charge of concealment and “furnishing of inaccurate particu…

Pr. Commissioner of Income Tax, Delhi-7 vs. Virtual Software and Training Pvt. Ltd

ITA/392/2023HC Delhi22 Nov 2024

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

Section 143Section 143(3)Section 271Section 271(1)Section 271(1)(c)Section 274

…would refer to inaccuracy which would cause underdeclaration or escapement of income. It may refer to particulars which should have been furnished or were required to be furnished or recorded in the books of account etc. (See CIT v. Raj Trading Co. [1996] 217 ITR 208 (Raj.)). Inaccuracy or wrong furnishing of income would be covered by the said expression, though there are decisions that ad hoc addition per se without other or corroborating circumstances may not reflect “furnished inaccurate particulars”. Lastly, at times and it is fairly common, the charge of concealment and “furnishing of inaccurate p…

Pr. Commissioner of Income Tax vs. M/S Hari Narain Parwal

ITA/90/2020HC Rajasthan21 Feb 2024

Bench: AVNEESH JHINGAN,SHUBHA MEHTA

Rakesh Gupta, New Delhi vs. ACIT Circle-34(1), New Delhi

In the result, the appeal of the assessee is allowed, as indicated above

ITA 7804/DEL/2019[2010-11]Status: DisposedITAT Delhi25 May 2022AY 2010-11

Bench: Shri Challa Nagendra Prasad, S.M.C. आ.अ.सं./ I.T.A No. 7804/Del/2019 िनधा"रणवष"/Assessment Year: 2010-11 Shri Rakesh Gupta, Acit, बनाम H – 87, Ashok Viohar, Circle : 34 (1), Phase – 1, Vs. New Delhi. New Delhi – 110 052. Pan No. Aewpg7366R अपीलाथ" / Appellant ""यथ" / Respondent

For Appellant: N o n eFor Respondent: Shri Om Parkash, Sr. D. R
Section 10(38)Section 148Section 271(1)(c)Section 274Section 68Section 69C

…sued for multiple defaults, no penalty can be levied. The assessee also relied on the decision of the Hon’ble Delhi High court in the case of New Holland Tractors India Pvt. Ltd. (ITA. No. 182/2002). Hon’ble Rajasthan High Court in the case of Raj Trading Co. 217 ITR 208 (Raj.) and also the decisions of Delhi Tribunal in the case of M.G. Contractors Pvt. Ltd. (ITA. No. 7034/Del/2014) and Poysha Goyal (ITA. No. 1721/Del/2013). However, it is observed that the ld. CIT (Appeals) referring to the decision of the Hon’ble Bombay High Court in the case of CIT Vs. Smt. Kaushlaya 216 ITR 660 (Bom.) and also the decision o…

Rohidas Hari Jathar, Thane vs. ACIT Circle-4, Mumbai, Thane

In the result, the impugned order is quashed and the appeal of assessee is allowed

ITA 961/MUM/2019[2010-11]Status: DisposedITAT Mumbai26 Oct 2020AY 2010-11

Bench: Shri Vikas Awasthy & Shri Rajesh Kumarआअसं. 961/मुं/2019 (िन. व. 2010-11) Rohidas Hari Jathar A-102, Magdha Chs Ltd. Chanakya Nagari, Samel Village, Nallasopara (W) Thane- 401203 ...... अपीलाथ$ /Appellant Pan: Adipj2562M बनाम Vs. Asst. Cit Circle-4, Room No.2, A Wing, Ashar I.T. Park, Ambika Nagar Wagle Estate, Thane-400604 ..... %ितवाद"/Respondent

For Appellant: NoneFor Respondent: Shri Vijay Jaiswal (DR)
Section 271(1)(c)Section 274

…rate act or omission on the part of the assessee. Such deliberate act must be either for the purpose of concealment of income or furnishing of inaccurate particulars.” 8. The Hon’ble Rajasthan High Court in the case of CIT vs. Raj Trading Company reported as 217 ITR 208 has also explained the difference between the two expressions i.e. “furnishing inaccurate particulars of income” and “concealment of income”. The relevant extract of the observations of the Hon’ble Rajasthan High Court are reproduced herein below: “5. .............. Furnishing incorrect particulars and concealing the particulars of income are dif…

Maitreya Plotters & Structures P.Ltd, Palghar vs. DCIT Cir 4, Thane

In the result, appeal filed by the assessee for assessment year 2012-

ITA 1254/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Sept 2019AY 2012-13

Bench: Shri M. Balaganesh (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2012-13 Maitreya Plotters & Structures The C.I.T. (Appeals)-3, Pvt. Ltd., A Wing, 6Th Floor, Ashar It Pt. Din Dayal Nagar, Park, Road 16Z, Vasai (West), Palghar - 401302 Vs. Wagle Industrial Estate, Pan: Aafcm9944B Thane - 400604 (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri J. Saravanan (DR)
Section 133Section 143Section 271Section 68

…the case of appellant, the AO establishes that there were concealment or furnishing inaccurate particulars of income, which justify initiating penalty proceedings. (e) Reliance is placed on various judicial pronouncements i) In CIT vs. Raj Trading Co. (1996) 217 ITR 208 (Raj) explaining the difference between the two held that the words furnishing inaccurate particulars of income, refer to the particulars which have been furnished by an assessee of income and the requirement of concealment of income is that income has not been declared at all or is not even been recorded in the books of accounts or in a particul…

DCIT, New Delhi vs. M/S. Granite Gate Properties Pvt. Ltd., New Delhi

ITA 2239/DEL/2014[2010-11]Status: DisposedITAT Delhi16 Dec 2016AY 2010-11

Bench: Shri H.S. Sidhu & Shri Anadi N Mishra

For Appellant: Shri Sanjeev Sapra, CAFor Respondent: Shri A.K. Saroha, CIT (DR)
Section 271

…FIT FOR PUBLICATION (JM) (AM) ITA Nos. 2239, 2240/Del/2014 INCOME TAX APPELLATE TRIBUNAL DELHI BENCH "C", NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI ANADI N MISHRA, ACCOUNTANT MEMBER ITA Nos.:- 2239, 2240/Del/2014 Assessment Years: 2010-11, 2011-12 DCIT, Circle 12 (1) M/s. Granite Gate Properties Pvt. New Delhi. Ltd. Vs. C-23, Greater Kailash Part-1, New Delhi - 110 048 PAN AADCR6248M (Appellant) (Respondent) Department by : Shri A.K. Saroha, CIT (DR) Assessee by: Shri Sanjeev Sapra, CA Date of Hearing 19/10/2016 Date of pronouncement 16/12/2016 O R D E R Per ANADI N MISHRA. A.M. (A)These a…

Shri Aditya Malla, Noida vs. ITO, Noida

In the result, appeal filed by the assessee stands partly allowed

ITA 2457/DEL/2016[2011-12]Status: DisposedITAT Delhi27 Jul 2016AY 2011-12

Bench: Shri G. D. Agrawal, Hon’Ble & Smt. Beena A. Pillai

For Appellant: Shri Pradip Dinodia. CAFor Respondent: Shri T. Vasanthan, Sr. DR
Section 24Section 271(1)(c)Section 80C

…Del/2016 to inaccuracy which would cause under declaration or escapement of income. It may also refer to particulars which should have been furnished or were required to be furnished or recorded in the books of account, etc. See CIT v. Raj Trading Co. [1996] 217 ITR 208/86 Taxman 282 (Raj). Inaccuracy or wrong furnishing of income would be covered by the said expression. II In the light of what has been stated by the Hon'ble jurisdictional High Court, it can be seen that the furnished particulars in the present case are certainly 'inaccurate'. 2.1 This case is also covered under the provisions of Explanation 1…

Commissioner of Income vs. Ng Technologies Ltd

The appeal is disposed of

ITA/82/2012HC Delhi01 Dec 2014
Section 260ASection 271(1)(c)

…ITA 82/2012 Page 1 of 14 $~ * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 1st December, 2014 + ITA No. 82/2012 COMMISSIONER OF INCOME ..... Appellant Through Mr. Rohit Madan, Sr. Standing Counsel with Mr. Ruchir Bhatia and Mr. Akash Vajpai, Advocates. versus NG TECHNOLOGIES LTD. ..... Respondent Through Mr. Ashish Makhija, Mr. Karamveer Jindal, Advocates for the Official Liquidator. CORAM: HON'BLE MR. JUSTICE SANJIV KHANNA HON…

New Holland Tractors (India) Private Limited

ITA/182/2002HC Delhi25 Sept 2014
Section 271(1)(c)

…refer to inaccuracy which would cause under-declaration or escapement of income. It may refer to particulars which should have been furnished or were required to be furnished or recorded in the books of accounts etc. [See CIT vs. Raj Trading Co. (1996) 217 ITR 208 (Raj.)] Inaccuracy or wrong furnishing of income would be covered by the said expression, though there are decisions that adhoc addition per se without other or corroborating circumstances may not reflect ―furnished inaccurate particulars‖. Lastly, at times and it is fairly common, the charge of concealment and ―furnishing of inaccurate par…

CIT v. Raj Trading Co. (217 ITR 208) — Cited in 10 Judgments | BharatTax