Price Waterhouse Coopers Pvt. Ltd. v. CIT

348 ITR 306Supreme Court of India2012#239 most cited

What is Price Waterhouse Coopers Pvt. Ltd. v. CIT authority for?

Penalty under section 271(1)(c) for furnishing inaccurate particulars cannot be imposed for a mere disallowance, bona fide mistake, or inadvertent error, especially when relevant facts are disclosed in the tax audit report. The levy of penalty requires proof of intent to conceal income or furnish false particulars.

313

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

Price Waterhouse Coopers v CIT · Section 271(1)(c) penalty · furnishing inaccurate particulars · concealment of income · bona fide mistake · inadvertent error · disallowance not penalty · tax audit report disclosure · Section 274 · SC 2012

Issues it is cited on

Judgments citing Price Waterhouse Coopers Pvt. Ltd. v. CIT

SS GROUP (P) LTD,HARYANA vs. ACIT CIRLCE-4(1), GURGAON, HARYANA

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

ITA 1094/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Sept 2025AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Sudhir Kumarm/S. Ss Group (P) Ltd., Vs. Acit, Circle 4 (1), Ss House, Plot No.77, Sector 44, Gurgaon. Sector 45, Gurgaon – 122 001 (Haryana). (Pan : Aadcr8945B) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Somil Agarwal, Advocate Shri Saksham Agarwal, Ca Revenue By : Ms. Amisha S. Gupt, Cit Dr Date Of Hearing : 14.08.2025 Date Of Order : 17.09.2025 O R D E R Per S.Rifaur Rahman,Am: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 07.02.2025 For The Assessment Year 2015-16 Affirming The Penalty Order Dated 21.03.2022 Passed U/S 271(1)(C) Of The Income-Tax Act, 1961 (For Short ‘The Act’).

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 271(1)(c)Section 40A(3)

…the Act cannot be charged with having concealed for furnished inaccurate particulars of income so as to impose penalty u/s 271(1)(c) of the Act by relying on the decision of Hon’ble Supreme Court in the case of Pricewaterhousecoopers Pvt. Ltd. vs. CIT (2012) 348 ITR 306. He relied on these decisions and prayed that the penalty levied on the assessee may be deleted. 3. Further ld. AR of the assessee submitted a letter dated 06.11.2017 which was submitted before the AO wherein it was submitted that assessee has submitted details of expenses in tax audit report in contravention to section 40A(3). Expenses were alre…

Showing 120 of 313 · Page 1 of 16

...