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“Section 271(1)(b)”

Section References (mined)Section 271Section 271(1)(b)1,252 judgments

The decision most relied on for Section 271(1)(b) is Hindustan Steel Ltd. v. State of Orissa (83 ITR 26), cited in 502 judgments on BharatTax.

Leading authorities on Section 271(1)(b)

Hindustan Steel Ltd. v. State of Orissa
83 ITR 26 · 1972 · Supreme Court
502
citing judgments

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

CIT v. Hero Cycles (P.) Ltd.
228 ITR 463 · 1997 · Supreme Court
262
citing judgments

A point not examined on facts or in law cannot be treated as a mistake apparent on record for rectification purposes.

CIT v. K.G. Rukminiamma
331 ITR 211 · 2011 · High Court
104
citing judgments

For capital gains exemption under Sections 54 and 54F of the Income Tax Act (prior to the 2015 amendment), the expression "a residential house" includes multiple residential units and should not be construed in the singular, by applying Section 13 of the General Clauses Act.

Velu Palandar v. DCIT
83 ITR 683 · 1972 · High Court
94
citing judgments

The opportunity of hearing provided to an assessee must be real, effective, and realistic, not merely notional, and tax authorities are incumbent to decide cases on their merits after affording due opportunity.

Duggal & Co. v. CIT
220 ITR 456 · 1996 · High Court
84
citing judgments

An assessment order becomes erroneous and prejudicial to the revenue under Section 263 if the Assessing Officer fails to conduct a proper inquiry or investigation, even if the return appears prima facie correct. The Income-tax Officer has a duty to investigate and cannot remain passive.

Maria Fernandes Cheryl v. ITO
187 ITD 738 · 2021 · ITAT
58
citing judgments

The third proviso to Section 50C(1) of the Income-tax Act, 1961, which provides a tolerance band of 10% between the sale consideration and the stamp duty value, is retrospective. This curative and declaratory amendment applies from the date of the insertion of Section 50C.

Addl. CIT v. J.K. D'Costa
133 ITR 7 · 1982 · High Court
57
citing judgments

Debatable issues cannot be rectified under Section 154 of the Income-tax Act, as rectification is limited to mistakes apparent from the record.

Akhil Bhartiya Prathamik Shikshak Sangh Bhawan Trust v. ADIT
5 DTR 429 · High Court
50
citing judgments

To levy a penalty under section 271(1)(b), the Assessing Officer (AO) must record satisfaction in the assessment order. Mere initiation of penalty proceedings without such recorded satisfaction does not confer jurisdiction on the AO to levy the penalty.

Judgments citing Section 271(1)(b)

Smt. Chameli Devi, Firozabad vs. ITO 5(1), Firozabad

Appeals are dismissed as withdrawn in above terms subject to all just exceptions

ITA 81/AGR/2023[2010-11]Status: DisposedITAT Agra10 Feb 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalita Nos. 79 To 81/Agr/2023 (Assessment Year 2010-11)

For Appellant: Ld. AR’s Letter dated 31-01-2025For Respondent: Sh.Shailendra Shrivastava, Sr. DR
Section 147Section 271(1)(b)

P a g e | 1 ITA Nos. 79 to 81/Agr/2023 Smt.Chameli Devi IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH

Smt. Chameli Devi, Firozabad vs. ITO5(1), Firozabad

Appeals are dismissed as withdrawn in above terms subject to all just exceptions

ITA 80/AGR/2023[201-11]Status: DisposedITAT Agra10 Feb 2025

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalita Nos. 79 To 81/Agr/2023 (Assessment Year 2010-11)

For Appellant: Ld. AR’s Letter dated 31-01-2025For Respondent: Sh.Shailendra Shrivastava, Sr. DR
Section 147Section 271(1)(b)

P a g e | 1 ITA Nos. 79 to 81/Agr/2023 Smt.Chameli Devi IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH

Smt. Chameli Devi, Firozabad vs. ITO, 5(1), Firozabad

Appeals are dismissed as withdrawn in above terms subject to all just exceptions

ITA 79/AGR/2023[2010-11]Status: DisposedITAT Agra10 Feb 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwalita Nos. 79 To 81/Agr/2023 (Assessment Year 2010-11)

For Appellant: Ld. AR’s Letter dated 31-01-2025For Respondent: Sh.Shailendra Shrivastava, Sr. DR
Section 147Section 271(1)(b)

P a g e | 1 ITA Nos. 79 to 81/Agr/2023 Smt.Chameli Devi IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH

Shiv Dutt Lohiya, Agra vs. CIT Appeal, Agra

Appeals are allowed in above terms

ITA 394/AGR/2024[2015-16]Status: DisposedITAT Agra07 Feb 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing)

Section 142(1)Section 271Section 271(1)(b)

hearing with the able assistance coming from the Revenue side that both the learned lower authorities have levied Rs.10,000/- penalty under section 271(1)(b) on the ground that the assessee had failed to comply not only the Assessing Officer’s section 142(1) notice(s) dated 15th, 25th

Shiv Dutt Lohiya, Agra vs. CIT Appeal, Agra

Appeals are allowed in above terms

ITA 393/AGR/2024[2013-14]Status: DisposedITAT Agra07 Feb 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing)

Section 142(1)Section 271Section 271(1)(b)

hearing with the able assistance coming from the Revenue side that both the learned lower authorities have levied Rs.10,000/- penalty under section 271(1)(b) on the ground that the assessee had failed to comply not only the Assessing Officer’s section 142(1) notice(s) dated 15th, 25th

Narayani Educational Health and Charitable Trust, Patna vs. DCIT, Central Circle-2, Patna

Appeals of the assessee are allowed for statistical purposes

ITA 303/PAT/2023[2016-17]Status: DisposedITAT Patna07 Feb 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Section 153CSection 250Section 263Section 271(1)(b)Section 273B

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA BENCH, PATNA VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and

Narayani Educational Health and Charitable Trust, Patna vs. DCIT, Central Circle-2, Patna

Appeals of the assessee are allowed for statistical purposes

ITA 302/PAT/2023[2015-16]Status: DisposedITAT Patna07 Feb 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Section 153CSection 250Section 263Section 271(1)(b)Section 273B

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA BENCH, PATNA VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and

Narayani Educational Health and Charitable Trust, Patna vs. DCIT, Central Circle-2, Patna

Appeals of the assessee are allowed for statistical purposes

ITA 301/PAT/2023[2013-14]Status: DisposedITAT Patna07 Feb 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.301 To 303/Pat/2023 Assessment Years: 2013-14, 2015-16 & 2016-17 Narayani Educational Health & Charitable Trust……..………….……Appellant A/78, P. C Colony, Kankarbagh, Patna, Bihar-800020. [Pan: Aactn2955K] Vs. Dcit, Central Circle-2, Patna....….….. ……………….........……...…..…..Respondent Appearances By: Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 Date Of Pronouncing The Order : February 07, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders All Dated 28.04.2023 Passed By The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2013-14, 2015-16 & 2016-17 Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Registry Has Informed That There Are Delays Of 106 Days In Filing All The Present Appeals. The Assessee Filed Applications For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Applications, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delays Were Not Intentional. We, Therefore

Section 153CSection 250Section 263Section 271(1)(b)Section 273B

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA BENCH, PATNA VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and

Chanakya Agro Products Pvt.Ltd, Patna vs. ITO, Ward-2(1), Patna

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

ITA 265/PAT/2024[2016-17]Status: DisposedITAT Patna31 Jan 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 265/Pat/2024 Assessment Year: 2016-2017 Chanakya Agro Products Pvt. Ltd.,……..……Appellant Hotel Samrat International, Fraser Road, Patna-800001, Bihar [Pan:Aabcc4937A] -Vs.- Income Tax Officer,…………………………...Respondent Ward-2(1), Patna Appearances By: Shri A.K. Rastogi, Advocate, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 03, 2025 Date Of Pronouncing The Order: January 31, 2025 O R D E R

Section 142(1)Section 143(2)Section 144Section 271(1)(b)

show cause notice was issued on 03.11.2018 intimating that non-compliance to notice under section 142(1) of the Act attract penalty under section 271(1)(b) of the Act as well as ex-parte assessment under section 144 of the Act would be made. Since the assessee failed

Income Tax Officer, Ward-1, Palanpur vs. Nikeshkumar Shantilal Mehta, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 2016/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad31 Jan 2025AY 2015-16
For Appellant: Shri Yashesh Mehta, CA, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 10Section 10(38)Section 142(1)Section 147Section 148Section 68

undisclosed income under Section 68 of the Act. Consequently, the total assessed income was computed at Rs.1,60,45,393/-. Penalty proceedings under Sections 271(1)(b) and 271(1)(c) of the Act were also initiated. 3. The CIT(A) deleted the addition of Rs.1

Ajinath Santram Kharat, Pune vs. Income Tax Officer, Ward-2(3), Nashik

In the result, appeal of the Assessee is allowed for

ITA 1771/PUN/2024[2015-16]Status: DisposedITAT Pune31 Jan 2025AY 2015-16
Section 143(3)Section 250Section 271(1)(b)Section 4Section 5Section 56(2)(vii)

having number 923588670281220 which is at page 56 of the paper book. Ld.AR demonstrated that the aid form was filed for Penalty under section 271(1)(b) of the Act, where as the Appeal dismissed by the ld.CIT(A) was against the addition made in the assessment order. We have ... perusal of Form No.3 explains that the Form No.3 is for Rs.10,000/- only which is a penalty under section 271(1)(b) of the Act. Ld.DR has accepted the facts. Thus there is apparent mistake in the order of the Ld.CIT(A). Ld.AR submitted that he had made

Dolphin Promoters and Builders, Raipur vs. Addl.CIT, Range-1, Raipur

ITA 58/RPR/2024[2011-12]Status: DisposedITAT Raipur30 Jan 2025AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 58/Rpr/2024 (िनधा"रण वष" Assessment Year: 2011-12)

For Appellant: Shri Sunil Kumar Agrawal & Vimal KumarFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(2)Section 144Section 250Section 271(1)(b)Section 68Section 801B(10)

आयकर अपीलीय अिधकरण, रायपुर "ायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR "ी रिवश सूद, "ाियक सद" एवं

Amarlal Thavardas Panjwani, Amravati vs. Income Tax Officer Ward-5, Amravati

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 262/NAG/2024[2013-14]Status: DisposedITAT Nagpur30 Jan 2025AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Abhay Y. Marathe
Section 144Section 271(1)(b)Section 271(1)(c)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

DCIT, Circle -6, Jaipur, Ncrb vs. Ascent Buildhome Developers Limited, Adarsh Nagar, Jaipur

In the result, the appeal of the revenue is dismissed

ITA 846/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Jan 2025AY 2013-14
For Appellant: Sh. Jitendra Wadhwa, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(1)Section 143(2)Section 143(3)

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

East West Finvest India Ltd., Indore vs. ACIT Central Circle, Bilaspur

In the result, appeal filed by the assessee company in ITA

ITA 9/RPR/2025[2019-20]Status: DisposedITAT Raipur29 Jan 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 6, 8 & 9/Rpr/2025 "नधा"रण वष" / Assessment Years : 2012-13, 2018-19 & 2019-20 East West Finvest India Ltd. 852, Sudama Nagar, In Front Of Jain Mandir, Indore-452 009 Pan : Aadec1236G

For Appellant: NoneFor Respondent: Smt. Tarannum Verma, Sr. DR
Section 142(1)Section 271(1)(b)Section 272A(1)(d)Section 274

compliance of notice u/s.142(1) of I.T. Act and failed to offer any explanation for the default committed. Thus, provision of Section 271(1)(b) of I.T. Act, 1961 is attracted in this case. Therefore, penalty for failure of comply with above three notices of Rs.10,000/- (Rs.10 ... challenged “that on the facts and circumstances of the case, initiation of penalty proceedings against the assessee under section 274 read with section 271(1)(b) and imposition of penalty of Rs.10,000/- upon the assessee under Section 271(1)(b) is illegal and unjustified and, therefore, penalty imposed should

East West Finvest India Ltd., Indore vs. ACIT Central Circle, Bilaspur

In the result, appeal filed by the assessee company in ITA

ITA 8/RPR/2025[2018-19]Status: DisposedITAT Raipur29 Jan 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 6, 8 & 9/Rpr/2025 "नधा"रण वष" / Assessment Years : 2012-13, 2018-19 & 2019-20 East West Finvest India Ltd. 852, Sudama Nagar, In Front Of Jain Mandir, Indore-452 009 Pan : Aadec1236G

For Appellant: NoneFor Respondent: Smt. Tarannum Verma, Sr. DR
Section 142(1)Section 271(1)(b)Section 272A(1)(d)Section 274

compliance of notice u/s.142(1) of I.T. Act and failed to offer any explanation for the default committed. Thus, provision of Section 271(1)(b) of I.T. Act, 1961 is attracted in this case. Therefore, penalty for failure of comply with above three notices of Rs.10,000/- (Rs.10 ... challenged “that on the facts and circumstances of the case, initiation of penalty proceedings against the assessee under section 274 read with section 271(1)(b) and imposition of penalty of Rs.10,000/- upon the assessee under Section 271(1)(b) is illegal and unjustified and, therefore, penalty imposed should

East West Finvest India Ltd., Indore vs. ACIT Central Circle, Bilaspur

In the result, appeal filed by the assessee company in ITA

ITA 6/RPR/2025[2012-13]Status: DisposedITAT Raipur29 Jan 2025AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 6, 8 & 9/Rpr/2025 "नधा"रण वष" / Assessment Years : 2012-13, 2018-19 & 2019-20 East West Finvest India Ltd. 852, Sudama Nagar, In Front Of Jain Mandir, Indore-452 009 Pan : Aadec1236G

For Appellant: NoneFor Respondent: Smt. Tarannum Verma, Sr. DR
Section 142(1)Section 271(1)(b)Section 272A(1)(d)Section 274

compliance of notice u/s.142(1) of I.T. Act and failed to offer any explanation for the default committed. Thus, provision of Section 271(1)(b) of I.T. Act, 1961 is attracted in this case. Therefore, penalty for failure of comply with above three notices of Rs.10,000/- (Rs.10 ... challenged “that on the facts and circumstances of the case, initiation of penalty proceedings against the assessee under section 274 read with section 271(1)(b) and imposition of penalty of Rs.10,000/- upon the assessee under Section 271(1)(b) is illegal and unjustified and, therefore, penalty imposed should

Gopalapillai Sreekumar, Sooranad, Kunnathoor vs. Income Tax Officer, Central Circle-2, Bbn, Central Circle-II

In the result, appeals of the assessee stand allowed

ITA 47/CTK/2025[2016-17]Status: DisposedITAT Cuttack28 Jan 2025AY 2016-17

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita No.45 45/Ctk/2025: Assessment Year : Assessment Year : 2014-15

For Appellant: Shri Subit Kumar SahuFor Respondent: Shri S.C.Mohanty, Sr DR
Section 142(1)Section 143(3)Section 144Section 153ASection 171(1)(b)Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH

Gopalapillai Sreekumar, Sooranad, Kollam, Kerala vs. Income Tax Officer, Central Circle-II, Bbn

In the result, appeals of the assessee stand allowed

ITA 46/CTK/2025[2015-16]Status: DisposedITAT Cuttack28 Jan 2025AY 2015-16

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita No.45 45/Ctk/2025: Assessment Year : Assessment Year : 2014-15

For Appellant: Shri Subit Kumar SahuFor Respondent: Shri S.C.Mohanty, Sr DR
Section 142(1)Section 143(3)Section 144Section 153ASection 171(1)(b)Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH

Gopalapillai Sreekumar, Kollam, Kerala vs. Income Tax Officer, Central Circle-2, Central Circle-II

In the result, appeals of the assessee stand allowed

ITA 45/CTK/2025[2014-15]Status: DisposedITAT Cuttack28 Jan 2025AY 2014-15

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalita No.45 45/Ctk/2025: Assessment Year : Assessment Year : 2014-15

For Appellant: Shri Subit Kumar SahuFor Respondent: Shri S.C.Mohanty, Sr DR
Section 142(1)Section 143(3)Section 144Section 153ASection 171(1)(b)Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH