CIT v. Reliance Petroproducts Pvt. Ltd.

322 ITR 158Supreme Court of India2010#9 most cited

What is CIT v. Reliance Petroproducts Pvt. Ltd. authority for?

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

2,080

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2026.

Also referred to as

CIT v. Reliance Petroproducts Pvt. Ltd. · 322 ITR 158 · penalty under section 271(1)(c) · furnishing inaccurate particulars · concealment of income · mere disallowance · difference of opinion · full disclosure · levy of penalty · no automatic penalty · section 274 · Supreme Court

Also reported as

189 Taxmann.com 322

Sections most often in play

Section 271(1)(c)Section 143(3)Section 274Section 250Section 148Section 14ASection 147Section 270A

Issues it is cited on

penalty under section 271(1)(c)furnishing inaccurate particularsfurnishing inaccurate particulars of incomepenalty u/s 271(1)(c)concealment of incomesection 271(1)section 274levy of penaltysection 271(1)(c)section 271section 27section 14a

Judgments citing CIT v. Reliance Petroproducts Pvt. Ltd.

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

…ton 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 also perused the judgment of the Hon’ble Supreme Court cited by the assessee supra and in the said judgment, it was held as follows: Page 6 of 6 “A mere making of a claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. Such claim made…

M/S. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(3)1, MUMBAI, MUMBAI

In the result, both appeals by the assessee are allowed

ITA 527/MUM/2026[2015-16]Status: DisposedITAT Mumbai15 Apr 2026AY 2015-16

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Ms. Vinita Shah, ARFor Respondent: Shri Anurag Tripathi, SR. AR
Section 115Section 143(3)Section 158ASection 250Section 271(1)(c)

…urt on the issue were upheld. 12. At this stage, it is also pertinent to note that while examining the meaning of the term “particulars” in section 271(1)(c) of the Act, the Hon’ble Supreme Court in CIT v/s Reliance Petroproducts (P) Ltd., reported in [2010] 322 ITR 158 (SC), held that mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. The relevant findings of the Hon’ble Supreme Court, in the case cited supra, are reproduced as follows: – “9. We are not concerned in the present case with the mens rea. H…

M/S. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(3)1, MUMBAI, MUMBAI

In the result, both appeals by the assessee are allowed

ITA 526/MUM/2026[2014-15]Status: DisposedITAT Mumbai15 Apr 2026AY 2014-15

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Ms. Vinita Shah, ARFor Respondent: Shri Anurag Tripathi, SR. AR
Section 115Section 143(3)Section 158ASection 250Section 271(1)(c)

…urt on the issue were upheld. 12. At this stage, it is also pertinent to note that while examining the meaning of the term “particulars” in section 271(1)(c) of the Act, the Hon’ble Supreme Court in CIT v/s Reliance Petroproducts (P) Ltd., reported in [2010] 322 ITR 158 (SC), held that mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. The relevant findings of the Hon’ble Supreme Court, in the case cited supra, are reproduced as follows: – “9. We are not concerned in the present case with the mens rea. H…

ACIT, CIRCLE-13(1), NEW DELHI vs. JALANDHAR AMRITSAR TOLLWAYS LTD, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 4214/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: NoneFor Respondent: Ms. Monika Singh, CIT-DR
Section 143(3)Section 43(1)

…there could be no levy of penalty under section 271(1)(c ) of the Act for disallowance of a claim made by the assessee. Reliance in this regard is placed on the decision of the Hon’ble Supreme Court in the case of CIT vs Reliance Petroproducts Ltd reported in 322 ITR 158 (SC) wherein it was categorically held that merely because the claim made by an assessee was not accepted by the revenue, the same would not result in levy of penalty under section 271(1)( c) of the Act. Hence respectfully following the same, we direct the learned AO to delete the entire penalty levied under section 271(1)(c ) of the Act in the f…

JALANDHAR AMRITSAR TOLLWAYS LTD.,NEW DELHI vs. DCIT, CIRCLE- 13(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 3927/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: NoneFor Respondent: Ms. Monika Singh, CIT-DR
Section 143(3)Section 43(1)

…there could be no levy of penalty under section 271(1)(c ) of the Act for disallowance of a claim made by the assessee. Reliance in this regard is placed on the decision of the Hon’ble Supreme Court in the case of CIT vs Reliance Petroproducts Ltd reported in 322 ITR 158 (SC) wherein it was categorically held that merely because the claim made by an assessee was not accepted by the revenue, the same would not result in levy of penalty under section 271(1)( c) of the Act. Hence respectfully following the same, we direct the learned AO to delete the entire penalty levied under section 271(1)(c ) of the Act in the f…

JALANDHAR AMRITSAR TOLLWAYS LTD.,NEW DELHI vs. DCIT, CIRCLE- 13(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 3926/DEL/2017[2012-13]Status: DisposedITAT Delhi27 Mar 2026AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: NoneFor Respondent: Ms. Monika Singh, CIT-DR
Section 143(3)Section 43(1)

…there could be no levy of penalty under section 271(1)(c ) of the Act for disallowance of a claim made by the assessee. Reliance in this regard is placed on the decision of the Hon’ble Supreme Court in the case of CIT vs Reliance Petroproducts Ltd reported in 322 ITR 158 (SC) wherein it was categorically held that merely because the claim made by an assessee was not accepted by the revenue, the same would not result in levy of penalty under section 271(1)( c) of the Act. Hence respectfully following the same, we direct the learned AO to delete the entire penalty levied under section 271(1)(c ) of the Act in the f…

JALANDHAR AMRITISAR TOLLWAYS LTD.,,NOIDA vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2921/DEL/2016[2011-132]Status: DisposedITAT Delhi27 Mar 2026AY 2011-132

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

For Appellant: NoneFor Respondent: Ms. Monika Singh, CIT-DR
Section 143(3)Section 43(1)

…there could be no levy of penalty under section 271(1)(c ) of the Act for disallowance of a claim made by the assessee. Reliance in this regard is placed on the decision of the Hon’ble Supreme Court in the case of CIT vs Reliance Petroproducts Ltd reported in 322 ITR 158 (SC) wherein it was categorically held that merely because the claim made by an assessee was not accepted by the revenue, the same would not result in levy of penalty under section 271(1)( c) of the Act. Hence respectfully following the same, we direct the learned AO to delete the entire penalty levied under section 271(1)(c ) of the Act in the f…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE, SHILLONG, SHILLONG vs. MEGHALAYA POWER TRANSMISSION CORPORATION LIMITED, LUMJINGSHAI, SHILLONG

In the result, the appeal of the Revenue is allowed

ITA 308/GTY/2025[2016-17]Status: DisposedITAT Guwahati13 Mar 2026AY 2016-17
Section 139(4)Section 139(9)Section 143(3)Section 144Section 263Section 271(1)(c)Section 72Section 80Section 80I

…m the P&L account\n\nThe jurisprudence on imposition-of-penalty holds t that while mens rea is not a\nstatutory requirement for penalty, the assessee's bona fide belief and disclosure can be\na valid defense, in CIT v. Reliance Petro products Pvt. Ltd. (2010) 322 ITR 158 (SC)\nthe Hon'ble Supreme Court held that making a claim which is not sustainable in law\ndoes not automatically amount to furnishing inaccurate particulars. Further the Court\nemphasized that mere disallowance of a claim does not justify penalty, unless the\nclaim is found to be false or mala fide. As observed above the claim was not intentional…

SHRI AJAY MAYOR,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1607/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S. N. Soparkar, Sr. Adv. &For Respondent: Shri C Dharani Nath, Sr. DR
Section 271(1)(c)Section 274

…n addition has been made in the assessment order does not automatically lead to the conclusion that the assessee has concealed income or furnished inaccurate particulars. The Hon’ble Supreme Court in the case of CIT vs. Reliance Petroproducts (P.) Ltd. (2010) 322 ITR 158 (SC) has categorically held that making an incorrect claim in law cannot amount to furnishing inaccurate particulars of income. The Court held that where all the facts relating to the claim are disclosed in the return of income and the claim Ajay Mayor vs. DCIT Asst. Year –2013-14 - 7– is made under a bona fide belief, the same cannot attract pen…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. UNIMED TECHNOLOGIES LIMITED, PANCHMAHAL

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

ITA 279/AHD/2026[2016-17]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2016-17

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 271Section 271(1)(c)Section 43A

…s. Penalty provisions being penal in nature require clear evidence of deliberate concealment or willful furnishing of incorrect particulars, which is absent in the present case. 5.5. The Hon'ble Supreme Court in CIT vs. Reliance Petroproducts Pvt. Ltd. (2010) 322 ITR 158 (SC) has held that mere making of an unsustainable claim does not amount to furnishing of inaccurate particulars. Similarly, the Hon'ble Supreme Court in K.C. Builders & Another vs. ACIT (2004) 265 ITR 562 (SC) has held that when the addition itself does not survive or the foundation for penalty is removed, the penalty must be deleted. Considerin…

KAPIL KHANDELWAL,BAREILLY, UTTAR PRADESH vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-I, BAREILLY , BAREILLY, UTTAR PRADESH

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 335/LKW/2025[2015-16]Status: DisposedITAT Lucknow27 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Kapil Khandelwal, Vs. Asstt. Commissioner Of 56, Moar Kothi, Gangapur, Bareilly Income Tax, Circle-I, Bareilly Pan: Aiypk4908M (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 27.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961, Wherein The Ld. Cit(A) Has Confirmed The Penalty Levied Upon The Assessee Under Section 271(1)(C) By The Ld. Ao On 17.03.2022 & Dismissed The Appeal Of The Assessee For The A.Y. 2015-16. The Grounds Of Appeal Are As Under: - “1. Because Requisite Satisfaction For Levy Of Penalty U/S 271(1)(C) If The Income Tax Act 1961 Was Not Recorded In The Regular Assessment Order Dated 22.12.2017 Passed A/S 100%, Therefore, Penalty Proceedings Got Wholly Vitiated & Consequently, The Id. "Cit(A)" Ought To Have Quashed The Penalty Order Dated 17.03.2022, Being Illegal, Bad-In-Law & Without Jurisdiction 2. Because The Show Cause Notice For Levy Of Penalty Under Section 271(1)(C) Of The Act Did Not Specify Under Which Limb Penalty Was Sought To Be Imposed I.E.. Whether On Account Of Concealment Of Income Or For Furnishing Inaccurate Particulars Of Income & Consequently, The Penalty Order Dated 17.03.2022 Passed By Faceless Assessing Officer Deserved To Be Quashed.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 10(38)Section 250Section 271(1)(c)

…e long term capital gains as sham transactions. It was submitted that penalty could not be imposed upon it until mens rea was established. He placed reliance on the decision of the Hon’ble Supreme Court in the case of CIT vs. Reliance Petro Products (P.) Ltd. 322 ITR 158 and submitted that penalty proceedings may be kept in abeyance in view of the fact that the assessee had filed an appeal before the ITAT Lucknow Bench. The ld. AO refused to consider the submissions of the assessee. He held that in the case of CIT vs. Reliance Petro Products (P.) Ltd. (supra), the Hon’ble Supreme Court had held that there must be…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of expenses on difference o…

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

…hout appreciating the fact that in the assessment order the "Inaccurate particulars" has not been mentioned at single place. Moreover, it is a settled position of law, settled by Hon'ble Apex Court in the case of CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC) and other catena of Judgments that mere disallowance of claim for expenditure by itself would not DCIT Vs M/s CCL & 1 Anr. tantamount to furnishing inaccurate particulars of income and all facts relating to same had been disclosed by assessee, penalty could not have been imposed. As such the penalty imposed only on additions/ disallowance of…

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