Dilip N. Shroff v. JCIT

291 ITR 519Supreme Court of India2007#113 most cited

What is Dilip N. Shroff v. JCIT authority for?

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

565

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

Dilip N. Shroff v. JCIT · Section 271(1)(c) · Section 274 · penalty notice invalidity · non-application of mind · concealment of income · furnishing inaccurate particulars · burden of proof Revenue · striking off irrelevant clauses · standard proforma notice · levy of penalty

Also reported as

210 CTR 228

Sections most often in play

Section 271(1)(c)Section 274Section 143(3)Section 132Section 153CSection 250Section 153ASection 270A
Read the full judgment

Issues it is cited on

penalty under section 271(1)(c)furnishing inaccurate particulars of incomefurnishing inaccurate particularspenalty u/s 271(1)(c)concealment of incomesection 274levy of penaltysection 271(1)section 271section 271(1)(c)section 27section 139(1)

Judgments citing Dilip N. Shroff v. JCIT

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1840/BANG/2025[2018-19]Status: DisposedITAT Bangalore22 Jan 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1839/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1838/BANG/2025[2016-17]Status: DisposedITAT Bangalore22 Jan 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1837/BANG/2025[2015-16]Status: DisposedITAT Bangalore22 Jan 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1836/BANG/2025[2014-15]Status: DisposedITAT Bangalore22 Jan 2026AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Raghuram Enterprises, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1835/BANG/2025[2013-14]Status: DisposedITAT Bangalore22 Jan 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian, JCIT
Section 132Section 139Section 139(1)Section 153CSection 250Section 271(1)(c)

…outside the books of account. In view of such admission, the appellant had agreed to enhance the net profit by 1% of turnover. The Ld. CIT(A) considered the judicial precedents relied upon by the appellant, including the decisions in Dilip Shroff reported in 291 ITR 519, Manjunatha Cotton & Ginning Factory reported in 35 taxmann.com 250 (Karnataka) and M.M. Gujamagadi reported in 290 ITR 168, and observed that these decisions were rendered in the context of penalty proceedings being independent and penalty not being automatic. However, the Ld. CIT(A) held that the facts of the appellant’s case were distinguishab…

Brij Gopal Construction Company (P) Ltd., New Delhi vs. ACIT, Central Circle-3, Delhi

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…in the quantum proceedings, 9 though relevant, are not conclusive or determinative of the penalty proceedings. Reliance is placed on the following judgments: i) 86 ITR 376 (SC) CIT v. Khoday Eswarsa ii) 123 ITR 457 (SC) Anantharam Veerasinghaiah vs. CIT iii) 291 ITR 519 (SC) Dilip N. Shroff v. JCIT iv) 292 ITR 11 (SC) T. Ashok Pai v. CIT v) 190 Taxman 157 (Del) CIT v. Arctic Investment (P) Ltd. vi) 145 Taxman 530 (Del) CIT v. Globe Sales Corporation vii) 219 ITR 267 (Del) CIT v. J. K. Synthetics Limited viii) 160 ITR 94 (AP) (FB) CIT V. H. Abdul Bakshi ix) 219 CTR 447 (Kar) Bhadra Advancing (P) Ltd. v. ACIT x) 2…

Income Tax Officer, Mumbai vs. Suresh Maneklal Sheth, Mumbai

The appeal of the assessee is allowed

ITA 4560/MUM/2024[2007-08]Status: DisposedITAT Mumbai11 Nov 2025AY 2007-08

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri. Swapnil Choudhary Sr. ARFor Respondent: 30.10.2025
Section 143(3)Section 250Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, VICE PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 4560/Mum/2024 (Assessment Year: 2007-08) Income Tax Officer, Mumbai Suresh Maneklal Sheth Room No. 126, 1st Floor, Kautilya 1 Kusum Niwas, Irla Vile Parle (W), Bhavan, G Block, Bandra Kurla Vs. Mumbai 400056 Complex, Bandra East, Mumbai 400051 PAN: AJMPS0119H Appellant) : Respondent) : Shri Prateek Jain Assessee by : Shri. Swapnil Choudhary Sr. AR Revenue by : 30.10.2025 Date of Hearing : 11.11.2025 Date of Pronouncement O R D E R Per Padmavathy S, AM: This appeal by the revenue is aga…

Sh.Mohit Batola, Dehradun vs. ACIT, CC, Ddn, Dehradun

In the result, appeal of the assessee is allowed

ITA 101/DDN/2024[2010-11]Status: DisposedITAT Dehradun30 Oct 2025AY 2010-11

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2010-11] Mohit Batola Vs Acit 155, Village Miyanwala Central Circle P.O.-Harrawala, Dehradun, Dehradun, Uttarakhand Uttarakhand-248001 Pan-Aftpb3533M Appellant Respondent Assessee By Shri Verendra Kalra, Ca Revenue By Shri S.K.Chaterjee, Cit Dr Date Of Hearing 05.08.2025 Date Of Pronouncement 30.10.2025 Order

Section 132Section 142(1)Section 143(2)Section 153ASection 153A(1)(a)Section 153A(1)(b)Section 250Section 271(1)(c)Section 274(1)

…eld that the standard proforma of notice under section 274 of the Act without striking of the irrelevant clauses would lead to an inference of non-application of mind by the Assessing Officer. The Hon'ble Supreme Court in the case of Dilip N. Shroff vs. JCIT, 291 ITR 519(SC) has also noticed that where the Assessing Officer issues notice under section 274 of the Act in the standard proforma and the inappropriate words are not deleted, the same would postulate that the Assessing Officer was not sure as to whether he was to proceed on the basis that the assessee had concealed the particulars of his income or furnis…

Manoj Kumar Gangadharan, Bhopal vs. ITO (It and Tp) Bhopal, Bhopal

In the result appeal of the assessee is dismissed

ITA 671/IND/2024[2018-19]Status: DisposedITAT Indore09 Oct 2025AY 2018-19

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 143(3)Section 24Section 250Section 253Section 270ASection 270A(9)(a)Section 274

…pectfully submitted that the such reduction of the loss has not resulted to additional tax liability if any payable by the assessee. Sir the reduction of the loss is not due to submission of the inaccurate particulars by the assessee. (Dilip N. Shroff VS CIT (291 ITR 519) (SC)] (Reliance Petro Products (P) Ltd (322 ITR 158 (SC)] 4. sir it is humbly submitted that due to the reduction in the loss there is no tax liability upon the assessee. Sir it is once again requested to you to kindly consider the facts and circumstance of the case, where in there is no defauilt of the assessee 4. Sir, it is pertinent to note…

Chundayil Kalam Girijadevi, Keralassery vs. ITO Ward 1 & Tps, Palakkad

ITA 564/COCH/2025[2018-19]Status: DisposedITAT Cochin22 Sept 2025AY 2018-19

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Padmnathan K.VFor Respondent: Smt. Leena Lal
Section 250Section 270ASection 271(1)(c)Section 4

…y is unsustainable because mere preferring a claim which is unacceptable to the Revenue does not ipso facto lead to levy of penalty. The Hon'ble Supreme Court in the cases of CIT vs. Reliance Petro Products Private Limited 322 ITR 158 (SC) and Dilip N. Shroff 291 ITR 519 (SC) has held that where the addition is made in respect of a bona fide claim, even if such claim is untenable according to the learned Assessing Officer, still no penalty could be levied under section 271(1)(c) of the Act. D. Where the appellant has made adequate disclosures in the return, the penalty under section 270A of the Act is not justif…

Income-Tax Officer-8(3)(1), Mumbai vs. Vibgyor Texotech Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4705/MUM/2025[2009-10]Status: DisposedITAT Mumbai09 Sept 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Suchitra Raghunath Kamble ()

Section 143(3)Section 147Section 271(1)(c)Section 274Section 292B

…halya's insistence that the previous proceedings supply justification and cure the defect in penalty proceedings has not met acceptance. [Para 186] Question No. 3: What is effect of Supreme Court's decision in Dilip N. Shroff v. Jt. CIT [2007] 161 Тахтап 218/291 ITR 519 (SC), on issue of non-application of mind when irrelevant portions of printed notices are not struck off ? In Dilip N. Shroff, case (supra) for the Supreme Court, it is of 'some significance that in the standard Pro-forma used by the Assessing Officer in issuing a notice despite the fact that the same postulates that inappropriate words and para…

DCIT Central Circle 7 (1) Mumbai, Mumbai vs. Panther Investrade Limited, Mumbai

In the result, both the Cross appeals no

ITA 416/MUM/2025[2003-04]Status: DisposedITAT Mumbai04 Aug 2025AY 2003-04

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Rajiv Khandelwal & Akash Kumar, ARsFor Respondent: Shri Virabhadra S. Mahajan (Sr. DR)
Section 271(1)(c)

…o consider two more aspects: (a) "the impact of non-discussion on the aspect of 'prejudice' in the first set of decisions)": (b) and "the effect of the decision of the Hon'ble Supreme Court in case of Dilip N. Shroff v. Joint Commissioner of Income-Tax [2007] 291 ITR 519 (SC) on the issue of non-application of mind where the relevant portions of the printed notices are not struck off . 7.2 While making observation on the judgment of Dilip N. Shroff, it was observed by the hon'ble Court that primary burden of proof is on the Revenue. The AO must satisfy himself that there is primary evidence to establish that the…

DCIT(Central Circle)-7(1), Mumbai vs. Panther Investrade Limited, Mumbai

In the result, both the Cross appeals no

ITA 415/MUM/2025[2002-03]Status: DisposedITAT Mumbai04 Aug 2025AY 2002-03

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Rajiv Khandelwal & Akash Kumar, ARsFor Respondent: Shri Virabhadra S. Mahajan (Sr. DR)
Section 271(1)(c)

…o consider two more aspects: (a) "the impact of non-discussion on the aspect of 'prejudice' in the first set of decisions)": (b) and "the effect of the decision of the Hon'ble Supreme Court in case of Dilip N. Shroff v. Joint Commissioner of Income-Tax [2007] 291 ITR 519 (SC) on the issue of non-application of mind where the relevant portions of the printed notices are not struck off . 7.2 While making observation on the judgment of Dilip N. Shroff, it was observed by the hon'ble Court that primary burden of proof is on the Revenue. The AO must satisfy himself that there is primary evidence to establish that the…

M/S Kumaon Mandal Vikash Nigam Ltd., Nanital vs. ACIT, Circle-3, Nanital

In the result, the appeal of the assesse is allowed

ITA 44/DDN/2025[2013-14]Status: DisposedITAT Dehradun09 Jul 2025AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

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

…under section 274 of the Act without striking of the irrelevant clauses M/s Kumaon Mandal Vikash Nigam vs. ACIT would lead to an inference of non-application of mind by the Assessing Officer. The Hon'ble Supreme Court in the case of Dilip N. Shroff vs. JCIT, 291 ITR 519(SC) has also noticed that where the Assessing Officer issues notice under section 274 of the Act in the standard proforma and the inappropriate words are not deleted, the same would postulate that the Assessing Officer was not sure as to whether he was to proceed on the basis that the assessee had concealed the particulars of his income or furnis…

Dakshina Kannada Nirmithi Kendra, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, all these 9 appeals filed by the assessee are allowed

ITA 747/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jun 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(1)Section 143(3)Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.739 to 747/Bang/2025 Assessment years: 2010-11 to 2013-14 & 2016-17 Dakshina Kannada Nirmithi Kendra, Vs. The Income Tax Officer, Mangalore, 3, Srinivasnagar S.O. Ward 1(1), 575 025. Mangalore. PAN: AAAAD 1743J APPELLANT RESPONDENT Appellant by : Shri Ravish Rao, CA Respondent by : Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 10.06.2025 Date of Pronouncement : 25.06.2025 O R D E R Per Bench 1. All these appeals are filed Dakshina Kannada…

Dakshina Kannada Nirmithi Kendra, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, all these 9 appeals filed by the assessee are allowed

ITA 746/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jun 2025AY 2016-17

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(1)Section 143(3)Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.739 to 747/Bang/2025 Assessment years: 2010-11 to 2013-14 & 2016-17 Dakshina Kannada Nirmithi Kendra, Vs. The Income Tax Officer, Mangalore, 3, Srinivasnagar S.O. Ward 1(1), 575 025. Mangalore. PAN: AAAAD 1743J APPELLANT RESPONDENT Appellant by : Shri Ravish Rao, CA Respondent by : Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 10.06.2025 Date of Pronouncement : 25.06.2025 O R D E R Per Bench 1. All these appeals are filed Dakshina Kannada…

Dakshina Kannada Nirmithi Kendra, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, all these 9 appeals filed by the assessee are allowed

ITA 745/BANG/2025[2013-14]Status: DisposedITAT Bangalore25 Jun 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(1)Section 143(3)Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.739 to 747/Bang/2025 Assessment years: 2010-11 to 2013-14 & 2016-17 Dakshina Kannada Nirmithi Kendra, Vs. The Income Tax Officer, Mangalore, 3, Srinivasnagar S.O. Ward 1(1), 575 025. Mangalore. PAN: AAAAD 1743J APPELLANT RESPONDENT Appellant by : Shri Ravish Rao, CA Respondent by : Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 10.06.2025 Date of Pronouncement : 25.06.2025 O R D E R Per Bench 1. All these appeals are filed Dakshina Kannada…

Dakshina Kannada Nirmithi Kendra, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, all these 9 appeals filed by the assessee are allowed

ITA 744/BANG/2025[2013-14]Status: DisposedITAT Bangalore25 Jun 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(1)Section 143(3)Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.739 to 747/Bang/2025 Assessment years: 2010-11 to 2013-14 & 2016-17 Dakshina Kannada Nirmithi Kendra, Vs. The Income Tax Officer, Mangalore, 3, Srinivasnagar S.O. Ward 1(1), 575 025. Mangalore. PAN: AAAAD 1743J APPELLANT RESPONDENT Appellant by : Shri Ravish Rao, CA Respondent by : Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 10.06.2025 Date of Pronouncement : 25.06.2025 O R D E R Per Bench 1. All these appeals are filed Dakshina Kannada…

Dakshina Kannada Nirmithi Kendra, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, all these 9 appeals filed by the assessee are allowed

ITA 743/BANG/2025[2012-13]Status: DisposedITAT Bangalore25 Jun 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(1)Section 143(3)Section 271(1)(c)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.739 to 747/Bang/2025 Assessment years: 2010-11 to 2013-14 & 2016-17 Dakshina Kannada Nirmithi Kendra, Vs. The Income Tax Officer, Mangalore, 3, Srinivasnagar S.O. Ward 1(1), 575 025. Mangalore. PAN: AAAAD 1743J APPELLANT RESPONDENT Appellant by : Shri Ravish Rao, CA Respondent by : Shri Balusamy N, Jt.CIT(DR)(ITAT), Bengaluru. Date of hearing : 10.06.2025 Date of Pronouncement : 25.06.2025 O R D E R Per Bench 1. All these appeals are filed Dakshina Kannada…