CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT v. Sivananda Steels Limited

231 ITR 65High Court#7338 most cited

What is CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT v. Sivananda Steels Limited authority for?

A penalty for concealment of income or furnishing inaccurate particulars is not leviable if the assessee has made a full and true disclosure of material facts. The absence of inaccurate particulars in the return means the conditions for penalty under Section 271(1)(c) are not met.

15

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2023.

Also referred to as

CIT Vs. Reliance Petro Products · CIT v. Sivananda Steels Limited · section 271(1)(c) · penalty · concealment of income · inaccurate particulars · full and true disclosure

Issues it is cited on

section 274(1)section 43b(f)section 2(45)section 36(l)(iii)section 211section 271(l)section 32(1)(iia)house property incomesection 140full and true disclosuresection 271(l)(c)additional depreciation

Judgments citing CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT v. Sivananda Steels Limited

South Eastern Coalfields Limited, Bilaspur vs. Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur

ITA 42/RPR/2023[2016-17]Status: DisposedITAT Raipur09 Jun 2023AY 2016-17

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Limited, Bilaspur vs. Assisstant Commissioner of Income Tax, Circle-1(1), Bilaspur

ITA 41/RPR/2023[2015-16]Status: DisposedITAT Raipur09 Jun 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Limited, Bilaspur vs. Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur

ITA 40/RPR/2023[2014-15]Status: DisposedITAT Raipur09 Jun 2023AY 2014-15

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Limited, Bilaspur vs. Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur

ITA 39/RPR/2023[2013-14]Status: DisposedITAT Raipur09 Jun 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Limited, Bilaspur vs. Jt. Commissioner of Income Tax (OSD), Circle-1(1), Bilaspur

ITA 66/RPR/2021[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

Assistant Commissioner of Income Tax, Circle -1(1), Bilaspur vs. South Eastern Coalfields Limited, Bilaspur

ITA 170/RPR/2018[2012-13]Status: DisposedITAT Raipur09 Jun 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Limited, Bilaspur vs. Deputy Commissioner of Income Tax, Circle -1(1), Bilaspur

ITA 167/RPR/2018[2012-13]Status: DisposedITAT Raipur09 Jun 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

The Deputy Commissioner of Income Tax, Circle 1(1)Bilaspur, Bilaspur(Cg) vs. The South Eastern Coal Fields Ltd., Bilaspur, Bilaspur(Cg)

ITA 97/BIL/2017[2011-12]Status: DisposedITAT Raipur09 Jun 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

The South Eastern Coal Fields Ltd., Bilaspur, Bilaspur(Cg) vs. The Dy. Commissioner of Income Tax, Circle, 1(1)Bilaspur, Bilaspur(Cg)

ITA 163/BIL/2017[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coal Fields Ltd., Bilaspur(Cg) vs. Deputy Commissioner of Income Tax, Circle -1(1), Bilaspur(Cg)

ITA 144/BIL/2017[2011-12]Status: DisposedITAT Raipur09 Jun 2023AY 2011-12

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

Deputy Commissioner of Income Tax, Circle -1(1), Bilaspur(Cg) vs. South Eastern Coal Fields Ltd., Bilaspur(Cg)

ITA 143/BIL/2017[2010-11]Status: DisposedITAT Raipur09 Jun 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

South Eastern Coalfields Ltd, Bilaspur(Cg) vs. Dy.. C.I.T.-1(1), Bilaspur(Cg)

ITA 156/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

The Dy. CIT- Cir.-1(1), Bilaspur(Cg) vs. South Eastern Coalfilds Ltd., Bilaspur(Cg)

ITA 152/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

…rs filed by the appellant company in the return of any of the earlier years. The Ld. AR placed reliance in the decision in CIT Vs. Reliance Petro Products (P) Limited 322 ITR 158; CIT Vs. Sivananda Steels Limited 256 ITR 683 (Mad); CIT Vs. Dhoolie Tea Co. Ltd 231 ITR 65 (Cal); Township Read Estate Developers (India) (P) Ltd Vs. ACIT 21 taxman.com 63 (Mum) and submitted that there is no element of either concealment of income or furnishing of inaccurate particulars of income in the return in view of provisions of section 271(1)(c) and hence, penalty imposed by the Ld. AO against the additions is incorrect and liab…

Taher Afsar Ali, Mumbai vs. ITO 24(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7577/MUM/2013[2006-07]Status: DisposedITAT Mumbai22 Jun 2016AY 2006-07

Bench: Shri Shailendra Kumar Yadav, Jm & Shri Rajesh Kumar, Am आयकर अपीऱ सं./I.T.A. No.7577/Mum/2013 (ननधधारण वषा / Assessment Year : 2006-07) Taher Afsar Ali, बनधम/ Income Tax Officer 24(1(2), 5 Nand Kishore Indl Estate, Pratyakshakar Bhavan, Vs. Off Mahakali Caves, Rdm Bandra-Kurla Complex, Andheri(E), Bandra (E), Mumbai. Mumbai-400051. स्थधयी ऱेखध सं./ Pan : Aabpa0014H

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(22)(e)Section 271(1)Section 271(1)(c)

…of income which is added or disallowed in the assessment. 5 7577/Mum/2013 12) The facts in our case are that the assessee has disclosed the facts. 13) The assessee relies on the following judgments in support of his explanation. a) CIT v Dholie Tea Co. Ltd. 231 ITR 65 (Cal) it was held that the revenue has to prove that the assessee had knowingly concealed his income. b) CIT v Rahuljee and Co. 250 ITR 225 (Del) it was held that if the explanation given by the assessee was bonafide, penalty u/s. 271(1)(2) will not be attracted. 14) Further the assessee did not willingly shown deemed dividend in return of income…

ADIT - 3(2), Mumbai vs. M/S. Linklaters (Formerly Known As Linklater & Paines), Mumbai

ITA 7085/MUM/2005[2000-2001]Status: DisposedITAT Mumbai04 Feb 2016AY 2000-2001
For Appellant: Shri Niraj ShethFor Respondent: Shri Jasbir Chauhan-DR
Section 143(3)Section 254(1)Section 271Section 271(1)(c)

…अिधकरण, ‘एल’ खंडपीठ आयकर अपीलीय अपीलीय अिधकरण खंडपीठ मुंबई मुंबई आयकर आयकर आयकर अपीलीय अपीलीय अिधकरण अिधकरण खंडपीठ खंडपीठ मुंबई मुंबई INCOME TAX APPELLATE TRIBUNAL,MUMBAI “L” BENCH सव"ी सव"ी सव"ी राजे"" सव"ी राजे"" राजे"", लेखा राजे"" लेखा लेखा सद"य लेखा सद"य सद"य एवं सद"य एवं एवं राम लाल नेगी एवं राम लाल नेगी राम लाल नेगी, , , , "याियक सद"य राम लाल नेगी "याियक सद"य "याियक सद"य "याियक सद"य Before S/Sh. Rajendra,Accountant Member & Ram Lal Negi,Judicial Member आयकर आयकर अपील अपील संसंसंसं/.ITA No.7081/Mum/2005,िनधा"रण िनधा"रण वष" वष"/Assessment Year-1996-97 आयकर आयकर अपील अपील िनधा"रण िनधा"रण वष" वष" ADIT-(IT)…