Dilip N. Shroff v. Jt. CIT

161 Taxmann 218Supreme Court of India2007#368 most cited

What is Dilip N. Shroff v. Jt. CIT authority for?

To attract penalty under Section 271(1)(c), *mens rea* is essential for furnishing inaccurate particulars, signifying a deliberate act or omission by the assessee; further, Section 271(1)(iii) grants discretionary power to the Assessing Authority regarding the penalty quantum.

236

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2025.

Also referred to as

Dilip N. Shroff v. Jt. CIT · penalty under section 271(1)(c) · mens rea · furnishing inaccurate particulars · concealment of income · deliberate act or omission · Assessing Officer discretion · section 271(1)(iii) · section 274

Also reported as

6 SCC 329

Sections most often in play

Section 271(1)(c)Section 274Section 271AABSection 143(3)Section 153ASection 132Section 270ASection 276C

Issues it is cited on

section 274(1)section 276csection 276penalty under section 271aabsection 43b(f)section 2(45)section 36(l)(iii)section 211section 271(l)section 32(1)(iia)house property incomesection 271aab

Judgments citing Dilip N. Shroff v. Jt. CIT

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2175/PUN/2025[2013-14]Status: DisposedITAT Pune22 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2173/PUN/2025[2012-13]Status: DisposedITAT Pune22 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2172/PUN/2025[2010-11]Status: DisposedITAT Pune22 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,KOLHAPUR vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2170/PUN/2025[2008-09]Status: DisposedITAT Pune22 Dec 2025AY 2008-09

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

SHRI DATTA SHETKARI SAHAKARI SAKHAR KARKHANA LTD,SHIROL vs. DCIT, CIR-1, KOLHAPUR, KOLHAPUR

In the result the appeal filed by the assessee in ITA

ITA 2169/PUN/2025[2007-08]Status: DisposedITAT Pune22 Dec 2025AY 2007-08

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

ROHINI MARUTI DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

ITA 1839/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.Nos.1837 to 1839/PUN/2025 (Assessment Year 2015-2016) 1. Amol Vasant Deshmukh ITO, Ward-6(2), Pune PAN : ASAPD 8899 C Tulsabai Vasant Deshmukh 2. vs. PAN : AWQPD 9715 M Rohini Maruti Deshmukh 3. PAN : BHKPD 1741 F All r/o Flat No.104, F-Wing, Madhukosh Society, Lagad Mala, Sinhagad Road, Wadgaon Khurd, Pune Maharashtra-411041 (Appellants) (Respondent) For Assessee : Shri Sarang Gudhate, CA For Revenue : Shri Manoj Tripathi, Addl.CIT Date of Hearing : 11.12.2025 Date o…

TULSABAI VASANT DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

ITA 1838/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.Nos.1837 to 1839/PUN/2025 (Assessment Year 2015-2016) 1. Amol Vasant Deshmukh ITO, Ward-6(2), Pune PAN : ASAPD 8899 C Tulsabai Vasant Deshmukh 2. vs. PAN : AWQPD 9715 M Rohini Maruti Deshmukh 3. PAN : BHKPD 1741 F All r/o Flat No.104, F-Wing, Madhukosh Society, Lagad Mala, Sinhagad Road, Wadgaon Khurd, Pune Maharashtra-411041 (Appellants) (Respondent) For Assessee : Shri Sarang Gudhate, CA For Revenue : Shri Manoj Tripathi, Addl.CIT Date of Hearing : 11.12.2025 Date o…

AMOL VASANT DESHMUKH,PUNE vs. INCOME TAX OFFICER, WARD 6(2), PUNE

In the result, all the appeals (ITA Nos

ITA 1837/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.Nos.1837 to 1839/PUN/2025 (Assessment Year 2015-2016) 1. Amol Vasant Deshmukh ITO, Ward-6(2), Pune PAN : ASAPD 8899 C Tulsabai Vasant Deshmukh 2. vs. PAN : AWQPD 9715 M Rohini Maruti Deshmukh 3. PAN : BHKPD 1741 F All r/o Flat No.104, F-Wing, Madhukosh Society, Lagad Mala, Sinhagad Road, Wadgaon Khurd, Pune Maharashtra-411041 (Appellants) (Respondent) For Assessee : Shri Sarang Gudhate, CA For Revenue : Shri Manoj Tripathi, Addl.CIT Date of Hearing : 11.12.2025 Date o…

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 263/CTK/2025[2019-20]Status: DisposedITAT Cuttack02 Dec 2025AY 2019-20

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

…d Meadows (supra) held that such show cause notices would not satisfy the requirement of law as notice was not specific. Merely issuing notice in general proforma will negate the very purpose of natural justice. Hon'ble Apex Court in the case of Dilip N Shraf 161 Taxmann 218 held that "the quasi criminal proceedings u/s 271(1)(c) of the Act ought to comply with the principles of natural justice". 15. We, therefore respectfully following the judgment of jurisdictional High Court in the case of PCIT V/s Kulwant Singh Bhatia (supra), decision of Coordinate Bench of Chennai in the case of DCIT V/s R. Elangovan (supra…

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 262/CTK/2025[2018-19]Status: DisposedITAT Cuttack02 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

…d Meadows (supra) held that such show cause notices would not satisfy the requirement of law as notice was not specific. Merely issuing notice in general proforma will negate the very purpose of natural justice. Hon'ble Apex Court in the case of Dilip N Shraf 161 Taxmann 218 held that "the quasi criminal proceedings u/s 271(1)(c) of the Act ought to comply with the principles of natural justice". 15. We, therefore respectfully following the judgment of jurisdictional High Court in the case of PCIT V/s Kulwant Singh Bhatia (supra), decision of Coordinate Bench of Chennai in the case of DCIT V/s R. Elangovan (supra…

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 261/CTK/2025[2017-18]Status: DisposedITAT Cuttack02 Dec 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

…d Meadows (supra) held that such show cause notices would not satisfy the requirement of law as notice was not specific. Merely issuing notice in general proforma will negate the very purpose of natural justice. Hon'ble Apex Court in the case of Dilip N Shraf 161 Taxmann 218 held that "the quasi criminal proceedings u/s 271(1)(c) of the Act ought to comply with the principles of natural justice". 15. We, therefore respectfully following the judgment of jurisdictional High Court in the case of PCIT V/s Kulwant Singh Bhatia (supra), decision of Coordinate Bench of Chennai in the case of DCIT V/s R. Elangovan (supra…

M/S NANDLAL KESHARDEO,RANCHI vs. ACIT, CENTRAL CIRCLE (1), RANCHI

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

ITA 15/RAN/2025[2016-2017]Status: DisposedITAT Ranchi12 Nov 2025AY 2016-2017

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 132(1)Section 132(4)Section 153ASection 271(1)(c)Section 271ASection 274

…d Meadows (supra) held that such show cause notices would not satisfy the requirement of law as notice was not specific. Merely issuing notice in general proforma will negate the very purpose of natural justice. Hon'ble Apex Court in the case of Dilip N Shraf 161 Taxmann 218 held that "the quasi criminal proceedings w/s 271(1)(c) of the Act ought to comply with the principles of natural justice" 12. In the case of DCIT V/s R. Elangovan Lid capra). Co-ordinate Bench, Chennai while dealing with the legal ground challenging the validity of notice issued u/s 274 r.ws. 271AAB of the Act had observed that; "It is cle…

KANHAIYALAL RAMESHWAR DAS,KOTA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

ITA 1454/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 Oct 2025AY 2014-15
For Appellant: Shri Rajnikant Bhatra, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR (Thru: V.C)
Section 132(1)Section 143(3)Section 153Section 154Section 271(1)Section 271(1)(c)

…erything would depend upon the return filed because that is the only\ndocument, where the assessee can furnish the particulars of his income. When\nsuch particulars are found to be inaccurate, the liability would arise. In Dilip N.\nShroff v. Joint CIT [2007] 6 SCC 329, this court explained the terms\n"concealment of income" and "furnishing inaccurate particulars". The court went\non to hold therein that in order to attract the penalty under section 271(1)(c),\nmens rea was necessary, as according to the court, the word \"inaccurate\"\nsignified a deliberate act or omission on behalf of the assessee. It went on t…

DCIT(IT)-3(2)(2), MUMBAI vs. MUREX SOUTHEAST ASIA PRIVATE LIMITED, SINGAPORE

The appeal of the Revenue is dismissed

ITA 1453/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jun 2025AY 2014-15
Section 250Section 271(1)Section 271(1)(c)

…at\neverything would depend upon the Return filed because that is the only\ndocument, where the assessee can furnish the particulars of his income When\nsuch particulars are found to be inaccurate, the liability would arise In Dilip N.\nShroff v. J. CIT (2007)6 SCC 329, this Court explained the terms "concealment\nof income" and "furnishing inaccurate particulars The Court went on to hold\ntherein that in order to attract the penalty under section 271(1)(c), mens rea was\nnecessary, as according to the Court, the word "inaccurate" signified a\ndeliberate act or omission on behalf of the assessee. It went on to ho…

DCIT, CIRCLE 22(2), NEW DELHI, NEW DELHI vs. SAHIL VACHANI, DELHI

Appeal of the Revenue stands dismissed

ITA 2604/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Jun 2025AY 2016-17

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Vikas Awasthy& Shriavdhesh Kumar Mishraआअसं.2604/िद"ी/2023(िन.व. 2016-17)

For Appellant: S/Shri Anuj Garg & Narpat Singh, Sr.DRFor Respondent: S/Shri Rohan Khare & Priyam
Section 271(1)(c)Section 54F

…आयकर अपीलीय अिधकरण िद"ी पीठ “ जी ”, िद"ी "ी महावीरिसंह, उपा"" (तृतीयसद"), "ी िवकास अव"थी, "ाियक सद" एवं "ी अवधेशकुमारिम"ा, लेखाकार सद"के सम" IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”, DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESDIENT (THIRD MEMBER), SHRI VIKAS AWASTHY, JUDICIAL MEMBER& SHRIAVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER आअसं.2604/िद"ी/2023(िन.व. 2016-17) ITA N0.2604/DEL/2023(A.Y.2016-17) Dy. Commissioner of Income Tax 22(2), R.No 225E, 2nd Floor, CR Building, IP Estate, New Delhi 110002 ...... अपीलाथ"/Appellant बनाम Vs. Sahil Vachani, S-43, Panchsheel Park, Delhi 110017 PAN: ADJPV-6597-K .....…

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

ITA 5677/MUM/2024[2019-20]Status: DisposedITAT Mumbai28 Mar 2025AY 2019-20

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

ITA 3753/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

ITA 3752/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Mar 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

ITA 3751/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

ITA 3747/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

…at everything would depend upon the Return filed because that is the only document, where the assessee can furnish the particulars of his income. When such particulars are found to be inaccurate, the liability would arise. In Dilip N. Shroff v. Jt. CIT [2007] 6 SCC 329, this Court explained the terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee. It went on to hold…

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