“concealment of income”

PenaltySection 271(1)(c)Section 271(1)(c)2,901 judgments

PRAVIN VASANT MEHTA,MUMBAI vs. CIRCLE41(4)(1), KAUTILYA BHAVAN

In the result, the appeal of the assessee stands allowed

ITA 9024/MUM/2025[2009-2010]Status: DisposedITAT Mumbai26 Mar 2026AY 2009-2010

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 143(3)Section 147Section 271(1)(c)

considered view, the very edifice of penalty under section 271(1)(c) collapses in the absence of any cogent material demonstrating either concealment of income or furnishing of inaccurate particulars. The estimation of gross profit, howsoever justified for quantum purposes, cannot ipso facto lead to penalty, as it remains within

NARAYAN BARTER PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER,WARD-6(1),KOLKATA, KOLKATA

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

taxable at the rate of 30% u/s 115BBE of the Act. Penalty proceedings under section 271(1)(c) were also initiated for concealment of income of ₹81,50,000/-. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered the observation

BHANUSHANKAR KASALSHIBHAI DAVE,SURAT vs. ITO, WARD-3(2)(6), SURAT

In the result, the appeal of the assessee is allowed

ITA 1331/SRT/2025[2012-13]Status: DisposedITAT Surat19 Mar 2026AY 2012-13

For Appellant: \nShri Mehul Shah, ARFor Respondent: \nShri Ajay Uke, Sr. DR

Section 271(1)(c)

relates to\n Assessment Year (A.Y.) 2012-13.\n2. At the outset itself, Ld. Counsel for the assessee stated that\npenalty for concealment of income was levied on the assessee on\naccount of addition made to the assessee's income of cash\ndeposited in his bank account during the impugned

MAHESH VISHINDAS CHANDWANI,MUMBAI vs. DY CIT, CIRCLE 29(2), MUMBAI

In the result the Ground No

ITA 6777/MUM/2025[2013-14]Status: DisposedITAT Mumbai18 Mar 2026AY 2013-14

Section 143(2)Section 143(3)Section 250

total income of the assessee treating it as unexplained advances.\nPenalty proceedings u/s 271(1)(c) of the I.T. Act is initiated for concealment of income”.\n\n9. The Ld. DR argued and stands in favor of the order of revenue authorities.\n\n10. In our considered view, the assessee

AKSHIT MAHESH KARIA,MUMBAI vs. ITO WARD 3(2), MUMBAI

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

ITA 6052/MUM/2025[2015-16]Status: DisposedITAT Mumbai16 Mar 2026AY 2015-16

Section 142(1)Section 148Section 250Section 271(1)(b)Section 274

issue in hand, we hereby reproduce the\nrelevant provision for ease of reference:\n“1 [271. Failure to furnish returns, comply with notices, concealment of income, etc. —\n(1) If the 2 [Assessing Officer] or the ( ***) [Joint Commissioner (Appeals)] or the\n[Commissioner (Appeals)] or the [Principal Commissioner or Commissioner

SHRI AJAY MAYOR,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1607/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S. N. Soparkar, Sr. Adv. &For Respondent: Shri C Dharani Nath, Sr. DR

Section 271(1)(c)Section 274

invoking provision/s 271(1)(c) of the Act ignoring submission of the appellant that there is neither concealment of income nor furnishing inaccurate particulars of income which leads to invocation of penalty. 2. Ld. CIT(A) failed to appreciate that ld. AO failed to record proper satisfaction as to penalty ... concealment of income or furnishing inaccurate particulars of income and without proper satisfaction penalty order required to be quashed. It be so held now. 3. Ld. CIT(A) ought to have considered that amount received on dissolution of trust is capital receipt whereas it is treated as revenue in nature

DAZZLER CONFECTIONERY COMPANY PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 3(1)(1, MUMBAI

In the result, the Assessee’s Appeal is allowed

ITA 8411/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Mar 2026AY 2013-14

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankar

For Appellant: Mr. Rahul Sarda, Ld. ARFor Respondent: Shri Annavaram Kosuri, SR AR

Section 250Section 271(1)(c)Section 274Section 35D

Assessment Order, also initiated the penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income and concealing the income. 3. Thereafter, the Assessing Officer issued statutory notice dated 28.03.2016 u/s 274 r.w.s 271 of the Act for the following limb/charges:  Has concealed the particulars ... particulars of income meaning thereby without specifying any specific charge/limb. The AO further vide penalty order, ultimately levied the penalty under consideration for concealment of income OR furnishing inaccurate particulars of income, which goes to show that the AO while levying penalty was also confused and/or unclear qua limb/charge

ITO, WARD- 2(5), DEHRADUN vs. UTTRAKHAND POORV SAINIK KALYAN NIGAM LTD., DEHRADUN

In the result, the appeal of the Revenue is dismissed

ITA 3023/DEL/2018[2013-14]Status: DisposedITAT Dehradun12 Mar 2026AY 2013-14

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 10Section 143(3)Section 158ASection 250Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

DAWAT E ISLAMI AP,HYDERABAD vs. ITO., EXEMPTION WARD 1(1), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1575/HYD/2025[2015-16]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.1575/Hyd/2025 ("नधा"रणवष"/ Assessment Year: 2015-16) Dawat E Islami Ap, Vs. Income Tax Officer, Hyderabad. Exemption Ward-1(1), Pan: Aabtd5383Q Hyderabad. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Ankit Chokshi, Ca (Hybrid Mode) Assessee Represented By राज"वका""त"न"ध"व/ : Shri Mathivanan S A, Sr. Ar Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 05/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 11/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Dawat E Islami Ap, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 25/07/2025 For The A.Y.2015-16. Dawat E Islami Ap Vs. Ito

Section 12ASection 271(1)Section 271(1)(c)Section 274Section 275

Thus, the notice does not specify whether the penalty proceedings were initiated for Page 4 of 10 Dawat E Islami AP vs. ITO concealment of income or for furnishing inaccurate particulars of income. We further find that an identical issue has been adjudicated by this Tribunal in para

KURUZU RUSSELIAN,CHENNAI vs. ITO, NCC-22(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the penalty levied u/s

ITA 2830/CHNY/2025[2015-16]Status: DisposedITAT Chennai11 Mar 2026AY 2015-16

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. R. Subramanian, CAFor Respondent: Ms. R. Anitha, Addl. CIT

Section 147Section 148Section 271(1)(c)

accepting the returned income. Simultaneously, the AO initiated penalty proceedings u/s.271(1)(c) of the Act on the same date for alleged concealment of income. 6. The AO observed that the assessee had not filed the return of income voluntarily within the prescribed time and had filed the return only ... 2830/Chny/2025 AO levied a penalty of Rs.48,29,183/- u/s.271(1)(c) of the Act vide order dated 29.09.2023 for concealment of income. 7. Aggrieved by the penalty order passed by the AO, the assessee preferred an appeal before the Ld.CIT(A). It is noted that there was a delay

SUMANTO PAUL,DELHI vs. THE ASSESSING OFFICER , INCOME TAX DEPARTMENT

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

ITA 8755/DEL/2025[2016-17]Status: DisposedITAT Delhi11 Mar 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Amitabh Shuklaassessment Year: 2016-17 Sumanto Paul, Vs The Assessing Officer, 139, Kohat Enclave, Assessment Unit, Pitampur, Income Tax Department, Delhi – 110 034. New Delhi. Pan: Aajpp4082C

For Appellant: Ms Shruti Gupta, Advocate &For Respondent: Shri Nitin Kumar Jaiman, Sr. DR

Section 147Section 250Section 271(1)(c)

Section 271(1)(c) of the Act dated 10.01.2024 for the year under consideration though issued, no notice has been issued alleging either concealment of income or furnishing inaccurate particulars of income made by the assessee which is mandatory failing which the entire proceedings is 2 vitiated and, thus, liable

DCIT, CIRCLE-1(1), DEHRADUN, SUBHASH ROAD DEHRADUN vs. STATE INFRASTRUCTURE AND INDUSTRIAL DEVELOPMENT CORPORATION OF UTTARAKHAND LTD. , I.T. PARK, SAHASTRADHARA ROAD, DEHRADUN

In the result, the appeal of the Revenue is dismissed

ITA 233/DDN/2025[2014-15]Status: HeardITAT Dehradun10 Mar 2026AY 2014-15

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2014-15] Dcit Vs State Infrastructure & Circle-1(1) Industrial Development Dehradun Corporation Of Uttarakhand- Uttarakhand Ltd., 29 Iie, Sahastradhara Road (It Park) Road, Haripuram, Dehradun, Uttarakhand Pan-Aahcs7324R Revenue Assessee Revenue By Shri Pramod Verma, Cit Dr Assessee By Shri Sahil Kala, Ca Date Of Hearing 09.03.2026 Date Of Pronouncement 10.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Revenue Against The Order Dated 22.09.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 19.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014-15. 2. Heard Both The Parties At Length. The Claim Of The Assessee Was That It Had Suo-Motto Withdrew The Inadvertent Amount Of Deduction Claimed U/S 80Ia Of The Act However, The Ao Has Levied The Penalty U/S 271(1)(C) Of The Act By Ao Which Was Confirmed By Ld. Cit(A). 3. Ld. Cit (A) By Observing That Under Identical Circumstances, Penalty Levied For Ay 2011-12 Was Deleted By His Predecessor. Since The Ld. Cit(A) Has Followed The Order For Ay 2011-12 Wherein Penalty Levied Under Identical Circumstances, Was Deleted Which Facts Has Not Been Controverted By The Revenue. The Relevant Observation Of Ld. Cit(A) While Deleting The Penalty Are Reproduced As Under:-

Section 143(3)Section 250Section 271(1)Section 271(1)(c)Section 40ASection 801ASection 80I

made by AO in assessment order and partly allowed the appeal of the assessee. 6.2 AO levied penalty u/s 271(1)(c) for concealment of income on part of the assessee for a sum of Rs.5,76,34,588/- (Rs. 5,74,49,588/-excess claimed u/s 801A

AMISH PRAVINCHANDRA VYAS,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, the question is answered in the negative, i

ITA 1924/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2013-14

Bench: Ld. CIT(A) who has confirmed the levy of penalty u/s.271(1)(c) of the Act and dismissed the assessee appeal.

Section 132Section 139(1)Section 153ASection 271(1)(c)Section 274Section 68Section 69

Rs.20,08,170/- being unaccounted cash purchase of property and therefore penalty proceedings u/s. 271(1)(c) of the Act was initiated for “concealment of income” in the assessment order. However in the penalty notice dated 29-11-2017, the Ld. A.O. striked off “concealed particulars of income” but ticked ... Officer passed penalty order u/s. 271(1)(c) dated 17-08-2020 imposing penalty of Rs.6,20,524/- for the alleged default of “concealment of income”, not for “furnishing inaccurate particulars of income”. 3. Aggrieved against the penalty order, assessee filed an appeal before Ld. CIT(A) who has confirmed

SHREYANS ANILKUMAR SHAH,NA vs. ARIVS.CIT(A), WARD 5, NAVSARI, NAVSARI

In the result, the appeal of the assessee stands allowed

ITA 786/SRT/2025[2010-11]Status: DisposedITAT Surat09 Mar 2026AY 2010-11

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.786/Srt/2025 िनधा"रण वष" /Assessment Year : 2010-11 Shreyans Anilkumar Shah The Ito बनाम 504, Rushabh Residency Ward-5 / Maneklal Road Navsari – 396 445 V/S. Nr. Telephone Exchnage Navsari – 396 445 "थायी लेखा सं./Pan: Aiqps 6441 P (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Ms. Chaitali Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 16/05/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2010-11. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Shreyans Anilkumar Shah Vs. Cit(A) Asst. Year : 2010-11

For Appellant: Ms. Chaitali Shah, CAFor Respondent: Shri Ajay Uke, Sr.DR

Section 250Section 271(1)(c)

income of the assessee @15% of the gross receipts, yet, it is not a case, wherein it is proved that the assessee has concealed his income or has furnished inaccurate particulars of income. The assessee had duly shown the commission income, but at a lesser rate. He, therefore, relying upon ... estimated at a higher rate, the same could not be held to be a case of furnishing of inaccurate particulars of income or concealment of income. 5. We find force in the aforesaid contention raised by the Ld. Counsel for the assessee. The impugned addition was made

ACHALA PUNJA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX NON CORPORATE CIRCLE 3(1), CHENNAI

In the result, the appeal of the assessee stands allowed

ITA 2630/CHNY/2025[2014-15]Status: DisposedITAT Chennai09 Mar 2026AY 2014-15

Section 139(1)Section 142(1)Section 143(2)Section 148Section 194Section 271(1)(c)Section 54

difference\nin appreciation of the evidence and interpretation of the provisions of section 54\nof the Act, and cannot be construed as concealment of income or furnishing of\ninaccurate particulars of income within the meaning of section 271(1)(c) of the\nAct. In view of the fact that ... lack of supporting vouchers. The Tribunal held that the disallowance arose from a difference in appreciation of evidence and interpretation of law, not concealment of income.", "result": "Allowed", "sections": ["271(1)(c)", "54"], "issues": "Whether the penalty levied under Section 271(1)(c) is sustainable when the underlying addition/disallowance forming

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

ITA 2577/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Mar 2026AY 2018-19

Section 132Section 142Section 142(1)Section 143(2)Section 153A

cover all the assessment years within the block period, the Appellate Tribunal had found that inasmuch as there was no evidence regarding concealment of income for the period from 1996-97 to 2000-01, the assessments for those years could not be re-visited based on the evidence that