How many judgments cite CIT v. SAS Pharmaceuticals?

146 judgments on BharatTax cite CIT v. SAS Pharmaceuticals (335 ITR 259), spanning 2012 to 2025.

Which sections of the Income Tax Act does CIT v. SAS Pharmaceuticals come up under?

It is most often cited in judgments turning on Section 271(1)(c), Section 133A, Section 143(3), Section 147, Section 148, Section 115BBE.

CIT v. SAS Pharmaceuticals

335 ITR 259High Court2011#695 most cited

What is CIT v. SAS Pharmaceuticals authority for?

No penalty under section 271(1)(c) can be imposed if the amount of tax sought to be evaded is nil under Explanation 4(c), such as when the assessment results in a refund even after an addition to income. The conditions stipulated in the explanations to section 271(1)(c) must be unambiguously met for penalty imposition.

146

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

CIT v. SAS Pharmaceuticals · section 271(1)(c) · Explanation 4(c) · penalty for concealment · furnishing inaccurate particulars · tax sought to be evaded · nil tax liability · assessment refund · survey action

Sections most often in play

Section 271(1)(c)Section 133A Section 143(3)Section 147 Section 148 Section 115BBE Section 69 Section 69A

Issues it is cited on

surrender of income penalty under section 271(1)(c)furnishing inaccurate particulars of income furnishing inaccurate particulars concealment of income penalty u/s 271(1)(c)section 274 section 271(1)section 133a levy of penalty section 271 section 133

Judgments citing CIT v. SAS Pharmaceuticals

CHATTANATHAN DEVARAJAN ,MUMBAI vs. INCOME TAX OFFICER 34(1)(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 4976/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Sept 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2014-15 Chattanathan Devarajan Income Tax Officer - 34(1)(1) 1101, Raheja Tipco Heights Mumbai Rani Sati Marg, Vs. Malad East Mumbai – 400067 (Pan: Abjpc6332P) (Assessee) (Respondent)

For Appellant: Shri Haridas Bhat, CAFor Respondent: Shri Virabhadra Mahajan, Sr. DR

Section 147Section 148Section 156Section 192Section 194Section 194ASection 271(1)(c)

…aimed before the ld. CIT(A) that assessment has resulted into refund without any payment of advance or self-assessment tax. Assessee relied on certain judicial precedents including that of Hon'ble High Court of Delhi in the case of CIT vs. SAS Pharmaceuticals 335 ITR 259 (Del). In this decision, reference was made to explanations 4, 5 and 5A of section 271(1)(c), that no penalty can be imposed unless conditions stipulated in these provisions are duly and unambiguously met. 6. Before us, ld. Counsel for the assessee referred to clause (c) of explanation 4 to section 271(1)(c) to state that the amount of tax sough…

ASSISTANT COMMISSIONER OF INCOME TA , JAIPUR vs. SHRI NATH CORPORATION, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

For Appellant: Shri Hemang Gargieya, Adv. &

Section 133ASection 271(1)(c)

…d upon number of judgments of honorable courts and Tribunal in his submissions.\nSome of the judgments on the issue are as under:-\nCommissioner of Income-tax v. SAS Pharmaceuticals [2011] 11 taxmann.com 207 (Delhi)/[2011] 199 Taxman 255 (Delhi) (Mag.)/[2011] 335 ITR 259 (Delhi)/[2011] 244 CTR 51 (Delhi)[08-04-2011]\nSome of the arguments made on behalf of the assesse as noted in the judgement are as under:-\n\"It was also argued that the legislative intent in connection with section 271 of the Act is further fortified from the various Explanations provided in the said provision. In this regard, Explanation 4 is…

ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR vs. JITENDRA KUMAR AGARWAL, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a

Section 133ASection 271(1)(c)

…ied upon number of judgments of honorable courts and Tribunal in his submissions. Some of the judgments on the issue are as under:- Commissioner of Income-tax v. SAS Pharmaceuticals [2011] 11 taxmann.com 207 (Delhi)/[2011] 199 Taxman 255 (Delhi) (Mag.)/[2011] 335 ITR 259 (Delhi)/[2011] 244 CTR 51 (Delhi)[08-04-20111 Some of the arguments made on behalf of the assesse as noted in the judgement are as under:- "It was also argued that the legislative intent in connection with section 271 of the Act is further fortified from the various Explanations provided in the said provision. In this regard, Explanation 4 is rel…

ASSISTANT COMMISSIONER OF INCOME-TAX, JAIPUR vs. ROYAL JEWELLERS, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

For Appellant: Shri Hemang Gargieya, Adv. &

Section 133ASection 271(1)(c)

…upon number of\njudgments of honorable courts and Tribunal in his submissions.\nSome of the judgments on the issue are as under:-\nCommissioner of Income-tax v. SAS Pharmaceuticals [2011] 11 taxmann.com\n207 (Delhi)/[2011] 199 Taxman 255 (Delhi) (Mag.)/[2011] 335 ITR 259\n(Delhi)/[2011] 244 CTR 51 (Delhi)[08-04-20111\nSome of the arguments made on behalf of the assesse as noted in the judgement\nare as under:-\n\"It was also argued that the legislative intent in connection with section 271 of the\nAct is further fortified from the various Explanations provided in the said\nprovision. In this regard, Explanation 4…

SHRI YASH PAUL MALHOTRA,JALANDHAR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1, JALANDHAR

In the result the appeal of the assessee is allowed

ITA 379/ASR/2024[2016-17]Status: DisposedITAT Amritsar13 Aug 2025AY 2016-17

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

Section 133ASection 143(3)Section 250Section 271Section 271(1)Section 271(1)(C)Section 271(1)(c)

…he prays that the additional disclosure should be accepted in toto in its true spirit and should not be subjected to penalty. Finally, the Ld. AR, relying upon the decision of the Hon’ble Delhi High court 5.5 in the case of CIT vs SAS Pharmaceuticals ( 2011 ) 335 ITR 259 ( Delhi ) he argued that concealment or furnishing of inaccurate particulars is relatable only in respect of a return being filed. In the instant case, he argued that on the date of survey, the stage of return filing is not yet reached and a penal provision could not be invoked simply on the basis of an assumption that the assessee would not have…

ARAVINDA BHUPATHIRAJU REP BY GPA HOLDER SRI KAR BAHADUR SRI RAJA,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE (INTERNAL TAXATION), VISAKHAPATNAM

In the result, appeal of the assessee is allowed

ITA 262/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam18 Jul 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A. (It). No.262/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Aravinda Bhupathiraju Vs. Asst. Cit (International Taxation) Rep. By. Gpa Holder Income Tax Office, Infinity Towers, K.A.R. Bahadur Sri Raja Sankaramatam Road Falt No. 502, Sky Aditya Apartment Visakhapatnam- 530016 Gitams Road, Yendada Andhra Pradesh Visakhapatnam – 530045 Andhra Pradesh [Pan:Bjopb0898P] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Smt A. Aruna, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparna Villuri, Sr. Ar

Section 144Section 148Section 271(1)(c)

…Hon’ble Supreme Court in the case of K.C. Builders (supra) held that when the additions made in the assessment are deleted in appeal, the penalty under section 271(1)(c) cannot be sustained. Further, the Hon’ble Delhi High Court in CIT v. SAS Pharmaceuticals [335 ITR 259] held that when the primary addition is deleted, the consequential penalty cannot survive. It is also trite law that penalty is not automatic and should be imposed only when there is deliberate concealment or furnishing of inaccurate particulars with intent to evade tax. In the present case, in view of the relief allowed in the quantum proceeding…

MONISH RANJAN DASGUPTA,KOLKATA vs. ITO, WARD - 61(3), KOLKATA

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

ITA 2447/KOL/2024[2016-17]Status: DisposedITAT Kolkata07 May 2025AY 2016-17

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 148Section 250Section 271(1)Section 271(1)(c)Section 80

…आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री प्रदीप कुमार चौबे, न्याधयक सदस्य एवं श्री राकेश धमश्रा, लेखा सदस्य के समक्ष Before SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. No.: 2447/KOL/2024 Assessment Year: 2016-17 Monish Ranjan Dasgupta ITO, Ward-61(3), Kolkata Vs. (Appellant) (Respondent) PAN: AFCPD5730R Appearances: Assessee represented by : Gautam Banerjee, AR. Department represented by : Sanjoy Paul, Addl. CIT, Sr. DR. Date of concluding the hearing : April 16th, 2025 Date of pronouncing the…

ANATEK SERVICES PVT LTD,MUMBAI vs. ITO WARD 14(1)(1), MUMBAI

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

ITA 368/MUM/2025[2002-03]Status: DisposedITAT Mumbai30 Apr 2025AY 2002-03

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

…he case of Principal of\nCommissioner of Income Tax vs. M/s. Richardson and Cruddas (1972) Ltd., ITA No.\n1101 of 2016, order dated 09.01.2019 and decision of Hon'ble Delhi High Court in the\ncase of CIT vs. SAS Pharmaceuticals, order dated 08.04.2011, (2011) 335 ITR 259\n(Del.).\n21. The ld. DR on the other hand vehemently opposed to the contentions of the ld. AR and\nstated that had there been no survey action, the assessee would not have declared the\nadditional income. The ld. DR further stated that the additional income was part of the\nbogus transaction availed by the assessee which was unearthed during the…

ANATEK SERVICES PVT LTD,MUMBAI vs. INCOME TAX OFFICER 14(1)(1), MUMBAI

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

ITA 367/MUM/2025[2001-02]Status: DisposedITAT Mumbai30 Apr 2025AY 2001-02

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

ANATEK SERVICES PVT LTD,MUMBAI vs. INCOME TAX OFFICER -14(1)(1), MUMBAI

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

ITA 366/MUM/2025[1999-00]Status: DisposedITAT Mumbai30 Apr 2025AY 1999-00

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Haridas BhatFor Respondent: Shri. Ram Krishn Kedia (SR. DR.)

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

…n the case of Principal of Commissioner of Income Tax vs. M/s. Richardson and Cruddas (1972) Ltd., ITA No. 1101 of 2016, order dated 09.01.2019 and decision of Hon’ble Delhi High Court in the case of CIT vs. SAS Pharmaceuticals, order dated 08.04.2011, (2011) 335 ITR 259 (Del.). 21. The ld. DR on the other hand vehemently opposed to the contentions of the ld. AR and stated that had there been no survey action, the assessee would not have declared the additional income. The ld. DR further stated that the additional income was part of the bogus transaction availed by the assessee which was unearthed during the surv…

BHAGWATI PRASAD KHANDELWAL ,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA, KOTA

In the result, ground No. 1 of the assessee is allowed

ITA 1494/JPR/2024[2018-19]Status: DisposedITAT Jaipur22 Apr 2025AY 2018-19

Bench: The Learned Ao & Treating The Same As Income From Other Sources. 2. The Assessee Craves Your Indulgence To Add, Amend Or Alter All Or Any Grounds Of Appeal Before Or At The Time Of Hearing.”

For Appellant: Shri Harsh Poddar, AdvocateFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 115BSection 133ASection 142(1)Section 143(2)Section 250Section 69

…agwati Prasad Khandelwal, Kota. Therefore, the provisions of Sec. 115BBE are not attracted in the case of the assessee. The following case laws are quoted in support :- (1) DCIT vs.Dr. Satish B. Gupta 2011 49 DTR (Ahd) Trib. 262 (2) CIT Vs. SAS Pharmceuticals 335 ITR 259 (Delhi HC) In the aforesaid decisions, it has been held that penal provisions are applicable with reference to return of income. Penal provisions cannot be made applicable on the ground that if there had been no survey, the assessee would not have disclosed the income or would have succeeded in concealing the income. It has been held in these de…

MUKESH KUMAR AHUJA,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA

In the result, this appeal of the assessee is allowed

ITA 109/JPR/2025[2019-20]Status: DisposedITAT Jaipur07 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajendra Sisodia, C.AFor Respondent: Mrs. Swapnil Parihar, JCIT-DR

Section 115BSection 127Section 133ASection 139Section 142Section 143(2)Section 143(3)Section 69

…es return of income. If assessee furnishes return of income including income offered during survey then there remains no undisclosed income Reliance is further placed on the decision of Hon’ble Delhi High Court in the case of CIT vs. SAS Pharmceuticals (2011) 335 ITR 259 (Delhi HC) ".........We, thus, answer the questions as formulated above, in favour of the assessee and against the Revenue finding no fault with the decisions of the CIT (A) as well as the Tribunal. As a result, this appeal is dismissed" In the aforesaid decisions, it has been held that penal provisions are applicable unless otherwise specified w…

ARCHANA ACHYUT SAIL,MUMBAI vs. NFAC, NFAC

In the result, both the appeals are allowed

ITA 5278/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai25 Mar 2025

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Sumit MantriFor Respondent: Shri Umesh Chandra Sinha

Section 133ASection 147Section 148Section 270ASection 271(1)(c)

…of the Act, no penalty can be levied under Section 271(1)(c) of the Act. The co-ordinate Bench of this Tribunal in Haresh Ghanshyamdas Makhija (supra) has taken a similar view placing reliance on the decision of Delhi High Court in CIT vs SAS Pharmaceuticals, 335 ITR 259 (Delhi). In such circumstances, we find that the penalty under Section 271(1)(c) of the Act could not have been levied and the appeal deserves to succeed. 16. Coming to ITA No. 5277/Mum/2024 for assessment year 2017-18, we have carefully considered the submissions in the context of the findings recorded by the authorities below. It is necessary…

ARCHANA ACHYUT SAIL,MUMBAI vs. NFAC, DELHI

In the result, both the appeals are allowed

ITA 5277/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai25 Mar 2025

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Sumit MantriFor Respondent: Shri Umesh Chandra Sinha

Section 133ASection 147Section 148Section 270ASection 271(1)(c)

RAMCHANDRAUDAYSINGHJADHAVRAO,PUNE vs. ACIT, CIRCLE-3, PUNE

ITA 1399/PUN/2024[2016-17]Status: DisposedITAT Pune24 Feb 2025AY 2016-17

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

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari

Section 133ASection 139(1)Section 139(4)Section 143(1)Section 271(1)(c)Section 45(2)

…ot show the same. Relying on the following decisions, he submitted that when income filed incorporating the income surrendered during survey and the same has been accepted, no penalty u/s 271(1)(c) of the Act is leviable: i) CIT vs. SAS Pharmaceuticals (2011) 335 ITR 259 (Del) ii) Prakash Mithalal Oswal vs. ITO vide ITA No.327/PUN/2019, order dated 18.05.2022 9. The Ld. DR on the other hand heavily relied on the orders of the Assessing Officer and the Ld. CIT(A). He submitted that the assessee never disclosed to the Department that the land was converted into stock in trade in financial year 2010- 11 and due taxe…

CHOUDHARY CONSTRUCTION CO.,GOREGAON -W vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 31(1), MUMBAI

ITA 4072/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Feb 2025AY 2011-12

Bench: Shri Sandeep Gosain & Ms. Padmavathy Svs. Acit, Circle – 31(1) Ms. Choudhari Mumbai – 400020. Constructions Co. 151/129, Sidharth Nagar, Road No. 5, Behind Cinemax Cinema, S.V. Road, Goregoan (W), Mumbai – 400062. Pan/Gir No. Aabfc2689N (Applicant) (Respondent)

Section 133ASection 143(3)Section 250Section 271(1)(c)

…rn filed by the assessee was also accepted, therefore there was no occasion for the department to levy penalty. In this regard Ld. AR relied upon the following judicial decisions: 4 M/s Choudhari Constructions Co, Mumbai 1. CIT VS SAS pharmaceutical [2011] 335 ITR 259 Delhi, 2. CIT Vs. Shankarlal nebhamal Uttamchandani, 311 ITR 327 (Guj). 3. CIT Vs Suraj Bhan, [2007], 294, ITR, 481 4. Ajay Sangari & Co Vs ACIT 140 TTJ 388 Chandigarh 7. It was also argued that while invoking penalty provisions U/s 271(1)(c) of the Act, once the AO was not sure regarding which limb of penalty provision he intends to press into,…

AMITABHA SANYAL,KOLKATA vs. ITO, WARD-58(4), KOLKATA, KOLKATA

In the result, the appeal of the assessee is partly allowed and the penalty levied is hereby deleted

ITA 359/KOL/2022[2011-2012]Status: DisposedITAT Kolkata05 Nov 2024AY 2011-2012

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Years: 2011-12 Amitabha Sanyal, Income Tax Officer, 108B, Block-F, New Alipore, Ward – 58(4), Kolkata, Kolkata – 700053 Vs Aayakar Bhawan, (Pan: Aleps2352J) Bamboo Villa, 169, A.J.C. Bose Road, Kolkata - 700014 (Appellant) (Respondent)

For Appellant: Shri Amitabha Sanyal, AssesseeFor Respondent: Shri P.P. Barman, CIT, Sr. DR

Section 139(1)Section 148Section 250Section 254(2)Section 271Section 271(1)(c)Section 275

…this case, since the assessed income and the returned income are the same, the machinery provision of penalty u/s 271(1)(c) fails. In this regard, we draw support from the of Hon'ble Delhi High Court decision in the case of CIT vs. SAS Pharmaceuticals [2011] 335 ITR 259 (Del). The Hon'ble High Court has expounded that penalty u/s 271(1)(c) can only be levied if in the course of proceedings, the A.O. is satisfied that there is an concealment or furnishing of inaccurate particulars. The words “in the course of any proceedings under this Act mean the assessment proceedings”. However, the question 'whether there is…

ASSISTANT COMMISSIONER OF INCOME TAX, KOLHPAUR vs. RBL BANK LTD, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

ITA 657/PUN/2024[2014-15]Status: DisposedITAT Pune30 Sept 2024AY 2014-15

Bench: SATBEER SINGH GODARA, JUDICIAL MEMBER, AND DR.DIPAK P. RIPOTE (Accountant Member)

Section 139(1)Section 143(2)Section 250Section 271Section 271(1)(c)

…. It is also now well settled that when a bona fide claim is made by the assessee, penalty cannot be imposed when the claim is overturned by the Assessing Officer. This principle has been reiterated by the Delhi High Court in CIT v. SAS Pharmaceuticals [2011] 335 ITR 259 (Del) (page 80 - 84 of the compilation, relevant para 13 at page 84). A.3. The claim made by assessee is based on professional opnion obtained from PWC 41. When the transaction was being contemplated, the assessee sought a legal opinion from Price Waterhouse Coopers, on the treatment of the premium being paid to take over the business of Royal Ba…

ASHOK GOYAI,HIMACHAL PRADESH vs. DCIT, CENTRAL CIRCLE-2, NOIDA

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

ITA 2779/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Sept 2024AY 2013-14

Bench: Shri Vikas Awasthyआअसं.2779/िद"ी/2024 (िन.व. 2013-14) Ashok Goyal H.No. 228/48, Ward No. 11, Devi Nagar (115), Tehsil Paonta Sahib, Sirmaur, Himachal Pradesh 173025 ...... अपीलाथ"/Appellant Pan: Abepg-4250-F

For Appellant: Ms. Tanya, AdvocateFor Respondent: Ms. Shivani Bansal, Sr. DR

Section 132Section 147Section 148Section 153ASection 271(1)(c)

…alty u/s. 271(1)(c) of the Act can be levied. The 3 penalty under aforesaid section can be levied only when there is some addition or disallowance. In support of her submissions she placed reliance on the following decisions:- (i) CIT vs. SAS Pharmaceuticals, 335 ITR 259 (Del); and (ii) Armoury International vs. ACIT in ITA No. 3299 of 2017 decided on 01.01.2019 2. Ms. Shivani Bansal, representing the department vehemently defended the impugned order and prayed for dismissing appeal of the assessee. The ld. DR submitted that but for search operation, the assessee would not have offered unexplained expenditure to…

PRAKASH CHAND SAINI,SIKANDRA vs. PCIT(CENTRAL)JAIPUR, JAIPUR

ITA 479/JPR/2024[2019-20]Status: DisposedITAT Jaipur01 Aug 2024AY 2019-20

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Shailendra Sharma, CIT-DR

Section 133ASection 139Section 143(2)Section 143(3)Section 263

…sclose. The duty to disclose income arises only at the time when the assessee furnish return of income. If assessee furnishes return of income including income offered during survey then there remains no undisclosed income b. CIT Vs. SAS Pharmceuticals (2011) 335 ITR 259 (Delhi HC) ".........We, thus, answer the questions as formulated above, in favour of the assessee and against the Revenue finding no fault with the decisions of the CIT (A) as well as the Tribunal. As a result, this appeal is dismissed” In the aforesaid decisions it has been held that penal provisions are applicable unless otherwise specified w…

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