Commissioner of Income Tax, Ahmedabad v. Reliance Petroproducts Pvt. Ltd.

3 SCR 510Supreme Court of India2010#15578 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2011 to 2025.

Sections most often in play

Section 133ASection 139(1)Section 143(3)Section 153ASection 271(1)(c)

Issues it is cited on

section 133(a)section 115jctax collected at sourcesurrender of incomedeletion of penaltysection 260afurnishing inaccurate particulars of incomepenalty under section 271(1)(c)advance taxprincipal commissioner of income-taxsection 153a(1)reasoned order

Judgments citing Commissioner of Income Tax, Ahmedabad v. Reliance Petroproducts Pvt. Ltd.

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)

…271 of the Act cannot be invoked as the mandatory ingredients thereof are not met at all. 11. He also sought to draw sustenance from the judgment of Supreme Court in the case of Commissioner of Income Tax, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. (2010) 3 SCR 510 wherein inter alia it has been held that unless the conditions under Section 271 (1)(c) of the Act exist in a particular case, penalty cannot be imposed and it was further held that 271 of the Act being a penal provision is required to be construed strictly. The following observations made in the said judgment were specifically referred to: "8. The…

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)

…ot met at all. ITA No. 267, 196 & 197/JPR/2024 25 Shri Nath Corporation & Ors., Jaipur. 11. He also sought to draw sustenance from the judgment of Supreme Court in the case of Commissioner of Income Tax, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. (2010) 3 SCR 510 wherein inter alia it has been held that unless the conditions under Section 271 (1)(c) of the Act exist in a particular case, penalty cannot be imposed and it was further held that 271 of the Act being a penal provision is required to be construed strictly. The following observations made in the said judgment were specifically referred to: "8. The…

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)

…271 of the Act cannot be invoked as the mandatory ingredients thereof are not met at all. 11. He also sought to draw sustenance from the judgment of Supreme Court in the case of Commissioner of Income Tax, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. (2010) 3 SCR 510 wherein inter alia it has been held that unless the conditions under Section 271 (1)(c) of the Act exist in a particular case, penalty cannot be imposed and it was further held that 271 of the Act being a penal provision is required to be construed strictly. The following observations made in the said judgment were specifically referred to: "8. The…

John Augusty Poomkudy, Kochi vs. ACIT Circle 1(2), Kochi

Appeal is allowed in above terms

ITA 621/COCH/2022[2008-2009]Status: DisposedITAT Cochin22 Aug 2024AY 2008-2009

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri CBM Warrier, CAFor Respondent: Smt. V. Swarnalatha, Sr. DR
Section 271(1)(c)Section 57

…ching fact that such a failure on assessee’s part in filing all the relevant details along with the return and lack of substantiation thereof on his part, would hardly invite the impugned penal provision as per CIT vs. Reliance Petro Products (P) Ltd., [2010] 3 SCR 510 (SC) wherein their lordships’ have settled the law that on each and every quantum addition/ disallowance does not attracts the impugned penal provision automatically. We find force in learned counsel’s vehement submissions for deleting the impugned penalty of Rs.75 lakhs. Ordered accordingly. 4. Delay of 02 days is condoned by considering the asse…

Balee Plastics P.Ltd, Mumbai vs. ITO WD 5(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 7663/MUM/2013[2009-10]Status: DisposedITAT Mumbai23 Feb 2021AY 2009-10
Section 133ASection 271(1)Section 271(1)(c)Section 69B

…the mandatory ingredients thereof are not met at all. 5 M/s. Balee Plastics Pvt. Ltd., 11. He also sought to draw sustenance from the judgment of Supreme Court in the case of Commissioner of Income Tax, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. (2010) 3 SCR 510 wherein inter alia it has been held that unless the conditions under Section 271 (1)(c) of the Act exist in a particular case, penalty cannot be imposed and it was further held that 271 of the Act being a penal provision is required to be construed strictly. The following observations made in the said judgment were specifically referred to: "8. The…

Commissioner of Income Tax vs. M/S Sas Pharmaceuticals

Appeal is dismissed

ITA/1058/2009HC Delhi08 Apr 2011

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

Section 271(1)(c)

…e Act cannot be invoked as the mandatory ingredients thereof are not met at all. 11. He also sought to draw sustenance from the judgment of Supreme Court in the case of Commissioner of Income Tax, Ahmedabad Vs. Reliance Petroproducts Pvt. Ltd. (2010) 3 SCR 510 wherein inter alia it has been held that unless the conditions under Section 271 (1)(c) of the Act exist in a particular case, penalty cannot be imposed and it was further held that 271 of the Act being a penal provision is required to be construed strictly. The following observations made in the said judgment were specifically referred to:…

Commissioner of Income Tax, Ahmedabad v. Reliance Petroproducts Pvt. Ltd. (3 SCR 510) — Cited in 6 Judgments | BharatTax