Union of India v. Dharmendra Textile Processors

306 ITR 277Supreme Court of India2008#141 most cited

What is Union of India v. Dharmendra Textile Processors authority for?

Penalty under Section 271(1)(c) of the Income-tax Act, 1961 is a strict civil liability, and willful concealment is not an essential ingredient for attracting it. The explanation appended to the section indicates this element of strict liability for concealment or furnishing inaccurate particulars of income.

489

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2009 to 2026.

Also referred to as

Union of India v. Dharmendra Textile Processors · 306 ITR 277 · section 271(1)(c) · penalty for concealment · furnishing inaccurate particulars · strict liability · civil liability · willful concealment not required · penalty assessment

Also reported as

174 Taxmann 571212 CTR 432

Sections most often in play

Section 271(1)(c)Section 143(3)Section 115JBSection 37(1)Section 147Section 14ASection 1961Section 148

Issues it is cited on

furnishing inaccurate particulars of incomefurnishing inaccurate particularspenalty u/s 271(1)(c)penalty under section 271(1)(c)concealment of incomesection 274levy of penaltysection 271(1)section 271section 271(1)(c)section 27section 115jb

Judgments citing Union of India v. Dharmendra Textile Processors

SHREE KRISHNA WOOLLEN MILLS PRIVATE LIMITED,MUMBAI vs. DCIT, MUMBAI

In the result, the appeal of the assessee is dismissed

ITA 6025/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Jan 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethshree Krishna Woollen Vs. Dcit Circle 15(3)(2), Aayakar Bhawan, Mills Pvt. Ltd. Mumbai-400020. Krishna Mills Compound, L. B.S. Marg, Bhandup West S.O, 400078, Mumbai. Pan/Gir No: Aabcs9353G (Appellant) (Respondent)

Section 143(3)Section 250Section 271Section 271(1)(c)

…ellant not only made a legally untenable claim but failed to disclose it properly in the computation, and the explanation was found to be neither substantiated nor bona-fide. The Hon'ble Supreme Court in Union of India v. Dharmendra Textile Processors [(2008) 306 ITR 277 (SC)] has clearly held that penalty under section 271(1)(c) is a civil liability and will follow from the objective act of concealment or fumishing of inaccurate particulars without the necessity to prove mens-rea. 6.6 The addition sustained in this case relates to interest compensation received over a prolonged litigation period which the asses…

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 1125/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2015-16

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

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

…25 Axis Bank Ltd. vs. ACIT, A.Ys. 2011-12 to 2015-16 4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant had not furnished any inaccurate particulars of income and it has relied upon judicial precedents and the accounting standards applicable to the Bank to claim the lease rent expense on SLM basis 1.8. The Hon'ble CIT(A) erred in law and…

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 1124/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2014-15

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

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

…25 Axis Bank Ltd. vs. ACIT, A.Ys. 2011-12 to 2015-16 4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant had not furnished any inaccurate particulars of income and it has relied upon judicial precedents and the accounting standards applicable to the Bank to claim the lease rent expense on SLM basis 1.8. The Hon'ble CIT(A) erred in law and…

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 1123/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

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

…25 Axis Bank Ltd. vs. ACIT, A.Ys. 2011-12 to 2015-16 4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant had not furnished any inaccurate particulars of income and it has relied upon judicial precedents and the accounting standards applicable to the Bank to claim the lease rent expense on SLM basis 1.8. The Hon'ble CIT(A) erred in law and…

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 1122/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2012-13

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

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

…25 Axis Bank Ltd. vs. ACIT, A.Ys. 2011-12 to 2015-16 4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant had not furnished any inaccurate particulars of income and it has relied upon judicial precedents and the accounting standards applicable to the Bank to claim the lease rent expense on SLM basis 1.8. The Hon'ble CIT(A) erred in law and…

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 1121/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2011-12

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinha

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

…25 Axis Bank Ltd. vs. ACIT, A.Ys. 2011-12 to 2015-16 4 Ahmedabad Bench of Tribunal in the order dealing with merits on the underlying issue. 1.7. The learned AO and Hon'ble CIT(A) erred in relying on the decision in case of Dharamendra Textiles Processors [306 ITR 277) (2008) (SC) without appreciating the fact that the same is not applicable to the instant case as the Appellant had not furnished any inaccurate particulars of income and it has relied upon judicial precedents and the accounting standards applicable to the Bank to claim the lease rent expense on SLM basis 1.8. The Hon'ble CIT(A) erred in law and…

PRIME PRODUCTS LIMITED,KANPUR vs. D.C.I.T. CIRCLE 2(1)(1), KANPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 514/LKW/2025[2013-14]Status: DisposedITAT Lucknow13 Jan 2026AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2013-14 M/S Prime Products Ltd., 87/8, Kalpi Vs. The Dy. Cit, Road, Kanpur Circle-2(1)(1), Kanpur Pan: Aaacp8239K (Appellant) (Respondent) Assessee By: Sh. Ashish Jaiswal, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 13.01.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac In Confirming The Penalty Under Section 271(1)(C) Levied By The Ld. Assessing Officer On 23.01.2022 For The Assessment Year 2013-14. The Grounds Of Appeal Are As Under:- “1. That On The Facts & In Law, The Order Passed By Ld. Cit (Appeals), Nfac U/S 250 Of The Act Is Bad In Law. 2 That On The Facts & In Law, The Ld. Cit(Appeals), Nfac Has Erred In Upholding Action Of Learned Ao In Levying Penalty Of Rs. 94,000/- Under Section 271(1)(C) Of The Income Tax Act, 1961. 3 That On The Facts & In Law, The Notice Issued For Levy Of Penalty Under Section 274 R.W.S 271(1)(C) Dated 14/02/2020 Is Vague & Defective Since, It Does Not Specify The Limb Under Which Penalty Under Section 271(1)(C) Was Initiated. 4 That On The Facts & In Law, The Ld. Cit(A) Nfac Has Erred In Not Appreciating That The Assessee Had Offered An Explanation. The Penalty Proceedings & The Consequent Order Are Invalid & Void Ab Initio As The Same Were Initiated & Levied Solely On The Basis Of An Affidavit Without Independent Evidence Of Concealment.

For Appellant: Sh. Ashish Jaiswal, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 132Section 153ASection 250Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 274Section 69

…d concealed the particulars of income to the extent of Rs. 3,13,000/- 2 Prime Products Limited A.Y. 2013-14 and thereafter relying upon the decisions of the Hon’ble Supreme Court in the case of Union of India vs. Dharmendra Textile Processors and Ors (2008) 306 ITR 277 (SC) and MAK Data Pvt. Ltd. vs. CIT (2013) 358 ITR 593, he levied a penalty of Rs. 94,000/-, being 100 percent of the tax sought to be evaded. 3. Aggrieved with the said levy of penalty, the assessee went in appeal before the NFAC. The ld. CIT(A) to whom the case was allotted went through the order of the ld. AO and confirmed the same. Ongoing th…

PRASAM RAKESH CHOUDHARY,GIRNAR SOCIETY, BAPURAO GALLI, ITWARI, NAGPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, BHOPAL , BHOPAL

Appeal is dismissed

ITA 529/IND/2025[2018 -2019]Status: HeardITAT Indore22 Dec 2025

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

…andards know that already reimbursed expense should not be claimed and more-so when the assessee has expert assistance of accountants and auditors? (b) Without prejudice to the above, the Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) decisively rejected the quasi-criminal characterization of penalty under Section Page 2 of 17 M/s. Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271(1)(c) is a civil liability. Willful concealment is not an essential ingredient for attrac…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), BHOPOAL, BHOPAL vs. M/S RASHTRIYA TAKNIKI SHIKSHAK PRASHIKSHAN EVAM ANUNSANDHAN SANSTHAN, BHOPAL

Appeal is dismissed

ITA 509/IND/2025[2014-15]Status: DisposedITAT Indore22 Dec 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

…andards know that already reimbursed expense should not be claimed and more-so when the assessee has expert assistance of accountants and auditors? (b) Without prejudice to the above, the Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) decisively rejected the quasi-criminal characterization of penalty under Section Page 2 of 17 M/s. Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271(1)(c) is a civil liability. Willful concealment is not an essential ingredient for attrac…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

Appeal are dismissed

ITA 914/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22
For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…ear statutory mandate of section\n2(24)(xviii) as amended with effect from 01.04.2016. It is trite that\njudicial interpretation cannot defeat explicit legislative language. The\nHon'ble Supreme Court in Union of India v. Dharmendra Textile\nProcessors (2008) 306 ITR 277 (SC) held that where the statute is clear,\nthere is no scope for reading into it any intention other than what is expressed.\nSimilarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was\nheld that where the statutory language is plain, external aids such as\nprecedents cannot be used to obscure or rewrite the legislative command.\n20. We…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

DCIT CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT , BODAKDEV AHMEDABAD

Appeal are dismissed

ITA 848/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21
For Appellant: \nShri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…ear statutory mandate of section\n2(24)(xviii) as amended with effect from 01.04.2016. It is trite that\njudicial interpretation cannot defeat explicit legislative language. The\nHon'ble Supreme Court in Union of India v. Dharmendra Textile\nProcessors (2008) 306 ITR 277 (SC) held that where the statute is clear,\nthere is no scope for reading into it any intention other than what is expressed.\nSimilarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was\nheld that where the statutory language is plain, external aids such as\nprecedents cannot be used to obscure or rewrite the legislative command.\n20. We…

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 847/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR
Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

…e clear statutory mandate of section 2(24)(xviii) as amended with effect from 01.04.2016. It is trite that judicial interpretation cannot defeat explicit legislative language. The Hon’ble Supreme Court in Union of India v. Dharmendra Textile Processors (2008) 306 ITR 277 (SC) held that where the statute is clear, there is no scope for reading into it any intention other than what is expressed. Similarly, in B. Premanand v. Mohan Koikal (2011) 4 SCC 266, it was held that where the statutory language is plain, external aids such as precedents cannot be used to obscure or rewrite the legislative command. ITA Nos.…

INCOME TAX OFFICER 19.1.1, PIRAMAL CHAMBER LAL BAUG vs. A J DIAM, MUMBAI

In the result, appeal filed by the revenue is dismissed in the above terms

ITA 3845/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Nov 2025AY 2011-12

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanito-19(1)(1), Mumbai A. J. Diam Room No. 501, Piramal Chamber, Vs. 304, 3Rd Floor, Deccan Vikas Chs Lalbaug, Mumbai-400 012. Ltd. 584/1/584, Vithalbhai Patel Road, Kothachiwadi, Mumbai- 400 004 Pan: Aaofa4830G (Appellant) (Respondent)

Section 143(3)Section 148Section 250Section 271(1)(c)Section 274

…A. J. Diam 5. Whether on the facts and circumstances of the case and in law, Ld. CIT(A) has erred in deleting the penalty levied, without appreciating the decision of the Hon'ble Supreme court in case of Union of India Vs Dharmendra Textiles Processors & ors(306 ITR 277), wherein it was held that explanation appended to sec. 271(1)(c) of the Act, entirely indicate the element of strict liability on the assessee for concealment OR for giving inaccurate particulars while filing return and that the said section has been enacted to provide for a remedy for loss of revenue ? 6. Whether on the facts and circumstances…

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…

INCOME TAX OFFICER 23 2 6 , MUMBAI vs. MANMOHAN DAULAL RATHI, MUMBAI

In the result, appeal filed by the revenue is dismissed

ITA 5467/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Nov 2025AY 2010-11
Section 10(38)Section 147Section 148Section 250Section 271(1)(c)

…) ?\"\n7. \"Whether on the facts and circumstances of the case and in law, Ld.\nCIT(A) has erred in deleting the penalty levied, without appreciating the\ndecision of the Hon'ble Supreme court in case of Union of India Vs\nDharmendra Textiles Processors & ors 306 ITR 277), wherein it was held\nthat explanation appended to sec. 271(1)(c) of the Act, entirely indicate the\nelement of strict liability on the assessee for concealment or for giving\ninaccurate particulars while filing return and that the said section has been\nenacted to provide for a remedy for loss of revenue ?\".\n8. \"Whether on the facts and circ…

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