← All Phrases

“Section 221(1)”

Section References (mined)Section 221Section 221(1)66 judgments

VIJAY STONE PRODUCT,SONEBHADRA vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, ALLAHABAD

In the result, the appeal of the assessee is allowed

ITA 4/ALLD/2019[2011-12]Status: DisposedITAT Allahabad10 Mar 2026AY 2011-12

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.-2011-12 Vijay Stone Product, Vs. Asstt. Commissioner Of Income Bari Dala, Sonebhadra-231001 Tax, Central Circle, Allahabad Pan: Aagfv4724J (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. Amalendu Nath Mishra, Cit Dr Date Of Hearing: 17.12.2025 Date Of Pronouncement: 10.03.2026 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)- 3, Lucknow Dated 29.10.2018 Wherein The Ld. Cit(A) Has Confirmed A Penalty Of Rs. 1 Lac Levied By The Assessing Officer Under Section 221 Of The Act Against The Total Levy Of Rs. 27,26,200/- Made By The Assessing Officer. The Grounds Of Appeal Are As Under:- “1. That In Any View Of The Matter Order Passed U/S 221(1) Of The It Act Imposing Huge Penalty & His Action As Partly Confirmed By The Commissioner Of Income Tax (Appeal) By Maintaining Penalty Of Rs. 1,00,000/- Is Unjustified & Incorrect In The Facts & Circumstances Of The Case. 2. That In Any View Of The Matter Tax Liability On The Basis Of Assessment Order As Created Is Not Correct At All Therefore The Question Of Maintaining Penalty Of Rs. 1,00,000/- Is Unwarranted In The Facts & Circumstances Of The Case. 3. That In Any View Of The Matter In The Facts & Circumstances Of The Case Penalty Order Passed By The Assessing Officer & His Action As Partly Confirmed By The Commissioner Of Income Tax (Appeal) Is Totally Incorrect & Illegal & Hence The Question Of Maintaining Penalty Does Not Arise & Therefore So Maintained Penalty Is Liable To Be Deleted In All Fairness & In Interest Of Justice.

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. Amalendu Nath Mishra, CIT DR
Section 153DSection 153D(1)(B)Section 220(2)Section 221Section 221(1)Section 276C(2)

demand of Rs. 02,72,62,103/- had been raised which became due for payment after 30.04.2013. On 30.04.2013, a notice under section 221(1) had been issued to the assessee and subsequently the ld. AO had also allowed installments, vide an order dated 30.06.2013, but records that the assessee ... made any payment. The ld. AO records that three more notices under section 221(1) were issued on 29.10.2013, 21.01.2014 and 28.02.2014 followed by a show cause notice under section 276C(2) on 3.11.2017. However, the assessee expressed its inability to make the payment. Subsequently, further notices under section 221

KARTHIK LAKSHMAN,CHENNAI vs. IYO, INTL TAXATIONWARD-1(2), CHENNAI

In the result, appeal of the assessee is allowed

ITA 2182/CHNY/2025[2024-25]Status: DisposedITAT Chennai30 Jan 2026AY 2024-25

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2182/Chny/2025 िनधा"रण वष" /Assessment Year: 2024-25

For Respondent: Ms. R.Kavitha, Addl. CIT
Section 143(1)Section 205Section 250

deducted at source for which form no.16 A have been produced by the assessee - deductee and consequently impugned demand notice issued under Section 221(1) of the Act cannot be sustained. Concerned respondent therefore, is required to be directed to give credit of tax deducted at source to the assessee

M.K. WOOD TRADING CORPORATION,LUCKNOW vs. DCIT/ACIT-1, LUCKNOW

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

ITA 504/LKW/2025[2020-21]Status: DisposedITAT Lucknow31 Dec 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 M. K. Wood Trading Corporation V. The Dcit/Acit-1 10, Basha Khera Lucknow New Takrohi, Indira Nagar Lucknow (U.P) Tan/Pan:Aarfm2443G (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 07.08.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Partnership Firm Engaged In The Business Of Timber Products. The Assessee Filed Its Return Of Income For The Year Under Consideration On 10.12.2020 Declaring A Total Income Of Rs.54,030/-. The Case Of The Assessee Was Selected For Scrutiny Assessment And, Accordingly, The Assessing Officer (Ao) Issued Statutory Notices To The Assessee. However, There Was No Response From The Side Of The Assessee. The Ao Finally Issued Show Cause Notice Under Section 144 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) Dated 21.3.2022, Vide Which The Ao

For Respondent: Shri R.R.N. Shukla, D.R
Section 143(3)Section 144Section 144BSection 68

filing of the appeal escaped the attention of the deponent also and that it was only when the assessee received a notice under section 221(1) of the Income Tax Act, 1961 (hereinafter called “the Act’), that the deponent had contacted the Counsel to enquire about the filing of appeal

LAXMI DHARAMSOTH,MANCHYA THANDA vs. ITO., WARD-1, WARANGAL

ITA 1249/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Us:

Section 147Section 148

inoperative email account. It was claimed by her that she had gathered about the assessment order only on 11/09/2023 when a notice under section 221(1) was served upon her. However, the CIT(A) did not find any merit in the explanation of the assessee regarding the inordinate delay involved

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS)-1(1), MUMBAI, MUMBAI vs. LAXMINARAYAN MANDIR TRUST, MUMBAI

In the result, the grounds of appeal raised by revenue

ITA 5653/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Nov 2025AY 2013-14

Bench: Shri Pawan Singh& Ms. Padmavathy S(Physical Hearing) Dcit (Exemptions) – 1(1), Mumbai Laxminarayan Mandir Trust 6Th Floor, Mtnl Building, Cumballa Vs Ground Floor, Bapu Bhai Vasi Hill, Pedder Road, Road, Vile Parle (West), Mumbai – 400026. Mumbai – 400056. [Pan: Aaatl2061J] Appellant / Revenue Respondent / Assessee

Section 221Section 221(1)Section 221(2)Section 254(1)Section 260A

circumstances of the case and in law, the Ld. CIT(A) erred in directing the Assessing Officer to recalculate the demand under section 221(1) in light of ITAT's order for A.Y. 2013-14, whereas the appeal Laxminarayan Mandir Trust before the Ld. CIT(A) pertains only ... that addition in the quantum assessment has ultimately been deleted by Tribunal in its order dated 18.09.2023. Thus, the penalty order passed under section 221(1), in any will not survive. Thus, we affirmed the order of ld. CIT(A) and direct the AO to pass order giving effect immediately

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4564/MUM/2025[2023-24]Status: DisposedITAT Mumbai07 Nov 2025AY 2023-24

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4563/MUM/2025[2022-23]Status: DisposedITAT Mumbai07 Nov 2025AY 2022-23

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4562/MUM/2025[2021-22]Status: DisposedITAT Mumbai07 Nov 2025AY 2021-22

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4561/MUM/2025[2020-21]Status: DisposedITAT Mumbai07 Nov 2025AY 2020-21

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4560/MUM/2025[2019-20]Status: DisposedITAT Mumbai07 Nov 2025AY 2019-20

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4559/MUM/2025[2018-19]Status: DisposedITAT Mumbai07 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

SAPPHIRE FOODS INDIA LIMITED,MUMBAI vs. OSD TDS CIRCLE 2(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4558/MUM/2025[2016-17]Status: DisposedITAT Mumbai07 Nov 2025AY 2016-17

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: Shri Ajit Jain & Shri SiddheshFor Respondent: Shri Virabhadra Mahajan, (SR. DR)
Section 194ASection 201Section 201(1)Section 250Section 40

learned JCIT(A) further erred in upholding the action of the learned TDS officer. Ground No. 5 The initiation of penalty proceedings under Sections 221(1) and 271C is unwarranted and be dropped, given the bona fide compliance by the Appellant and absence of any deliberate default. The Appellant craves

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 78/DDN/2024[2014-15]Status: DisposedITAT Dehradun29 Oct 2025AY 2014-15
Section 147Section 148Section 234ASection 271(1)(b)Section 69A

{ "clean_text": "ITA Nos.64, 78 & 79/DDN/2024\n\nIN THE INCOME TAX APPELLATE TRIBUNAL\nDEHRADUN “SMC & DB\" BENCH: DEHRADUN\nBEFORE SHRI

AKHILESH SINGHAL,RISHIKESH vs. INCOME TAX OFFICER, RISHIKESH

In the result, appeal of the assessee is allowed

ITA 64/DDN/2024[2014-15]Status: DisposedITAT Dehradun29 Oct 2025AY 2014-15
Section 147Section 148Section 234ASection 271(1)(b)Section 69A

{ "clean_text": "ITA Nos.64, 78 & 79/DDN/2024\n\nIN THE INCOME TAX APPELLATE TRIBUNAL\nDEHRADUN “SMC & DB\" BENCH: DEHRADUN\nBEFORE SHRI

FIROZ ALAM,SAHARANPUR vs. ITO WARD-3(3)(3), SAHARANPUR

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

ITA 346/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Oct 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalfiroz Alam, Income Tax Officer, Quila Nawab Ganj, Ward-3(3), Saharanapur. Chakrata Road, Vs. Saharanpur, Uttar Pradesh-247001. Pan-Afspa9199P (Appellant) (Respondent) Assessee By None Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 23/07/2025 Date Of Pronouncement 23/07/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A), In Short] Dated 28.08.2024 In Appeal No. Nfac/2017-18/10273096 Arising Out Of Order Passed U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 28.02.2023 For Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessment Was Reopened On The Basis Of The Information That Assessee Has Made Transaction Of Rs. 94,76, 190/- With A Company Who Was Indulged In Purchases & Sales Only On Papers Without Actual Moment Of Goods. Accordingly, The Order U/S 148A(D) Of The Act Was Passed & Notice U/S 148 Was Issued After Obtaining The Approval From The Competent Authorities. During The Firoz Alam Vs. Ito Course Of Reassessment Proceedings, The Assessee Never Appeared Nor Filed Any Reply Before The Ao And, Therefore, The Ao Proceed To Complete The Assessment Exparte By Making The Addition Of Rs.94,76,190/- As Unexplained Expenditure U/S 69C Of The Act Towards The Purchases Made From Two Parties.

Section 147Section 148Section 148ASection 221(1)Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI

DCIT., CIRCLE-8(1), HYDERABAD vs. LATE SAMA RAMACHANDRA REDDY L/R BY HIS WIFE SAMA YASHODHA, HYDERABAD

In the result, both the appeals of Revenue are allowed

ITA 1611/HYD/2014[2007-08]Status: DisposedITAT Hyderabad26 Sept 2025AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: NoneFor Respondent: Dr. Sachin Kumar
Section 140ASection 143(3)Section 153ASection 221(1)Section 249(4)

mind entirety of the case, in our considered view, the assessee is, in principle, covered by the scope of the penalty under section 221(1) of the Act in a case in which the though the assessee has not paid the admitted tax liability under section 140A, while filing ... income. We, therefore, answer the question referred to the special bench in affirmative and against the assessee. However, whether the penalty under section 221(1) r.w.s. 140A(1) is actually leviable on the facts of a particular case or not will depend on the facts of that case and depending

DCIT., CIRCLE-8(1), HYDERABAD vs. LATE SAMA RAMACHANDRA REDDY L/R BY HIS WIFE SAMA YASHODHA, HYDERABAD

In the result, both the appeals of Revenue are allowed

ITA 1065/HYD/2012[2007-08]Status: DisposedITAT Hyderabad26 Sept 2025AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: NoneFor Respondent: Dr. Sachin Kumar
Section 140ASection 143(3)Section 153ASection 221(1)Section 249(4)

mind entirety of the case, in our considered view, the assessee is, in principle, covered by the scope of the penalty under section 221(1) of the Act in a case in which the though the assessee has not paid the admitted tax liability under section 140A, while filing ... income. We, therefore, answer the question referred to the special bench in affirmative and against the assessee. However, whether the penalty under section 221(1) r.w.s. 140A(1) is actually leviable on the facts of a particular case or not will depend on the facts of that case and depending

GAJENDRA KUMAR,MAHOBA vs. INCOME TAX OFFICER WARD 2 (2)(4 ), BANDA

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

ITA 94/ALLD/2025[2017-2018]Status: DisposedITAT Allahabad28 Aug 2025AY 2017-2018

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2017-18 Gajendra Kumar, Vs. Income Tax Officer, 526, Rathaur Colony, Jaitpur, Ward-2(2)(4), Banda Belatal, Mahoba, U.P. Pan:Bitpk6827P (Appellant) (Respondent) Assessee By: Sh. Praveen Godbole, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 06.08.2025 Date Of Pronouncement: 28.08.2025 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) Passed Under Section 250 Of The Income Tax Act, 1961 On 3.01.2025, Dismissing The Appeal Of The Assessee Against The Orders Of The Ito, Ward-2(2)(4), Banda Dated 21.12.2019 Passed Under Section 144 Of The Income Tax Act. The Grounds Of Appeal Are As Under:- “1. That The Learned Cit (Appeal) Has Erred In Law & Facts In Disallowing Appeal & Confirming The Addition Made By A.O. Of Rs. 25, 90,414/- As Cash Deposits Into Bank Account Under Section 69A Of It Act, 1961 Because All Notices Were Issued U/S 250 Of The Act On Itba Portal & No Physical Notice Was Issued To Appellant On Address Mentioned In Filed Itr & Filed Appeal & Has Disallowed Appeal Without Considering This Fact That Appellant Lives At Village Jaitpur Post Belataal, District Mahoba (U.P.) & Is Unknown About Information Technology. 2. That The Learned Cit (Appeal) Has Erred In Law & Facts In Disallowing Appeal & Confirming The Addition Made By A.O. Of Rs. 25, 90,414/- As Cash Deposits Into Bank Account Under Section 69A Of It Act, 1961 Without Considering This Fact That Appeal Was Filed By Advocate Dinesh Gupta Who Was Expired & Email Id In Profile Of Appellant Was Update By Him. Appellant Was Unknown About Login Id & Password Of Portal & Email Id Which Was Maintained By Late Advocate Dinesh Gupta.

For Appellant: Sh. Praveen Godbole, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 142Section 142(1)Section 143(2)Section 144Section 221(1)Section 250Section 69A

aware of the login ID and password created by him for the portal. It was only when the assessee received a notice under section 221(1) for the recovery of demanded tax by speed post, then it came to his knowledge that the Advocate Sh. Dinesh Gupta, who had filed

AMANDIP SIINGH,HOUSE NO. NEAR NEHAR PATTI vs. ITO WARD 1, TARN TARAN, ITO WARD , TARN TARAN SARHALI ROAD

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

ITA 414/ASR/2024[2013-14]Status: DisposedITAT Amritsar22 Aug 2025AY 2013-14

Bench: Shri Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

Section 147Section 148Section 154Section 221(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, ‘DB’: AMRITSAR BEFORE SHRI UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SHRI BRAJESH

NARESH KUMAR,BALACHAUR vs. INCOME TAX OFFICER, NAWANSHAHR, NAWANSHAR

In the result, the appeal of the assessee bearing ITA No

ITA 59/ASR/2025[2015-16]Status: DisposedITAT Amritsar11 Aug 2025AY 2015-16

Bench: Sh. Udayan Das Gupta & Sh. Brajesh Kumar Singh

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 221(1)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. BRAJESH KUMAR

Showing 1–20 of 66 · Page 1 of 4