← All Phrases

“concealment of income”

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

The decision most relied on for concealment of income is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on concealment of income

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing concealment of income

Dy.DIT., (It)-3(1), Mumbai vs. Global Cricket Corporation Pvt.Ltd., Mumbai

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

ITA 4990/MUM/2011[2003-04]Status: DisposedITAT Mumbai27 Oct 2023AY 2003-04

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm & Dy. Cit(It) – 3(1) M/S. Global Cricket Corpn Pte Ltd. Scindia House, R. No. 132, 1St Floor, C/O. S. R. Batliboi & Co. Vs. 18Th Floor, Express Towers, N. M. Road, Mumbai- 38 Nariman Point, Mumbai-21 Pan/Gir No. Aabcg 7951 L (Revenue) : (Assessee) & Cross Objection No. 83/Mum/2012 (Arising Out Of Ita No.4990/Mum/2011) (Assessment Year: 2003-04) M/S. Global Cricket Corpn Pte Ltd. The Dy. Dit (It)-3(1) C/O. S R B C & Associates Mumbai- 400 038 14Th Floor, The Ruby, Vs. 29 Senapati Bapat Marg, Dadar (W), Mumbai-400 028 Pan/Gir No. Aabcg 7951 L (Assessee) : (Revenue) : Shri P J Pardiwala/Aarati Sathe Assessee By Revenue By : Shri Ajay Kumar Sharma : 16.10.2023 Date Of Hearing Date Of Pronouncement : 27.10.2023

For Respondent: Shri Ajay Kumar Sharma
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 9(1)(vi)

initiated the penalty proceeding u/s. 271(1)(c) of the Act for furnishing of inaccurate particulars of income and for concealment of income. The ld. A.O. vide order dated 31.03.2010 passed u/s. 271(1)(c) of the Act levied a penalty of Rs.35,41,86,182/-. 5. Aggrieved, the assessee ... that the notice issued by the ld. A.O. has not struck off the irrelevant limb as to whether the penalty was levied for concealment of income or for furnishing inaccurate particulars of income. The ld. AR 4 ITA Nos.171/Mum/2008, 4990/Mum/2011, 4182/Mum/2011 & CO No. 83/Mum/2012 M/s. Global Cricket Corpn

The ADIT (It)-3(1), Mumbai vs. M/S. Global Cricket Corpn Pte. Ltd, Mumbai

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

ITA 171/MUM/2008[2002-2003]Status: DisposedITAT Mumbai27 Oct 2023AY 2002-2003

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm & Dy. Cit(It) – 3(1) M/S. Global Cricket Corpn Pte Ltd. Scindia House, R. No. 132, 1St Floor, C/O. S. R. Batliboi & Co. Vs. 18Th Floor, Express Towers, N. M. Road, Mumbai- 38 Nariman Point, Mumbai-21 Pan/Gir No. Aabcg 7951 L (Revenue) : (Assessee) & Cross Objection No. 83/Mum/2012 (Arising Out Of Ita No.4990/Mum/2011) (Assessment Year: 2003-04) M/S. Global Cricket Corpn Pte Ltd. The Dy. Dit (It)-3(1) C/O. S R B C & Associates Mumbai- 400 038 14Th Floor, The Ruby, Vs. 29 Senapati Bapat Marg, Dadar (W), Mumbai-400 028 Pan/Gir No. Aabcg 7951 L (Assessee) : (Revenue) : Shri P J Pardiwala/Aarati Sathe Assessee By Revenue By : Shri Ajay Kumar Sharma : 16.10.2023 Date Of Hearing Date Of Pronouncement : 27.10.2023

For Respondent: Shri Ajay Kumar Sharma
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 9(1)(vi)

initiated the penalty proceeding u/s. 271(1)(c) of the Act for furnishing of inaccurate particulars of income and for concealment of income. The ld. A.O. vide order dated 31.03.2010 passed u/s. 271(1)(c) of the Act levied a penalty of Rs.35,41,86,182/-. 5. Aggrieved, the assessee ... that the notice issued by the ld. A.O. has not struck off the irrelevant limb as to whether the penalty was levied for concealment of income or for furnishing inaccurate particulars of income. The ld. AR 4 ITA Nos.171/Mum/2008, 4990/Mum/2011, 4182/Mum/2011 & CO No. 83/Mum/2012 M/s. Global Cricket Corpn

Saamag Developers Pvt. Ltd., New Delhi vs. DCIT, Central Circle-19, New Delhi

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

ITA 2513/DEL/2018[2008-09]Status: DisposedITAT Delhi25 Oct 2023AY 2008-09

Bench: Shri N.K. Billaiya & Shri Challa Nagendra Prasad

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri T. James Singson, CIT-DR
Section 153ASection 271(1)Section 271(1)(c)Section 274

penalty notice dated 10.02.2016 reads as under: 8. In the first penalty notice, it is not discernible whether the penalty was leviable for concealment of income or for furnishing of inaccurate particulars of income. 9. At para 7 of the order by which the Assessing Officer has levied penalty

Vikas Sharma, Durg vs. Income Tax Officer-1(2), Bhilai, Durg

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 256/RPR/2023[2015-16]Status: DisposedITAT Raipur25 Oct 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 256/Rpr/2023 "नधा"रण वष" / Assessment Year : 2015-16 Vikas Sharma Quarter No.6-A, Ruabandha Sector, Bhilai, Dist. Durg (C.G.)-490 006 Pan : Ddcps1720P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Bhilai, Durg (C.G.) ……""यथ" / Respondent

For Appellant: S/shri Sakshi Gopal Aggarwal &For Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 250Section 271(1)(c)Section 274Section 68

perusal of penalty order, it is noticed that the A.O. has imposed penalty of Rs.3,96,743/- u/s 271(1)(c) for concealment of income. In the assessment order, the A.O. has made addition of Rs.10,20,000/-; on account of unexplained cash credit u/s 68 of the Income ... imposed by 4 Vikas Sharma Vs. Income Tax Officer-1(2), Bhilai the A.O of Rs.3,96,743/- u/s. 271(1)(c) for concealment of income. Accordingly, the appeal of the appellant is not allowed. 6. In result, the appeal is not allowed.” 5. The assessee, being aggrieved with

J.P Tobaco Producta Pvt. Ltd vs. Asst. Commissioner of Income Tax Circle - Sagar

In the result, both the appeals filed by the assessee are In the result, both the appeals filed by the assessee are In the result, both the appeals filed by the assessee are allowed

ITA 188/JAB/2016[2003-04]Status: DisposedITAT Jabalpur20 Oct 2023AY 2003-04

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 187 & 188/Jab/2016 Assessment Years: 2002-03 & 2003-04 J.P. Tobacco Products Pvt. Ltd., Acit Circle-Sagar. Pathariya Phatak, Damoh (M.P.) Vs. Pan No. Aaacj 7141 G Appellant Respondent Assessee By : Mr. G.N. Purohit, Sr. Advocate & Mr. Abhijeet Shrivastava, Advocate Revenue By : Mr. Saad Kidwai, Cit-Dr : Date Of Hearing 22/09/2023 Date Of Pronouncement : 20/10/2023

For Appellant: Mr. G.N. Purohit, Sr. Advocate &For Respondent: Mr. Saad Kidwai, CIT-DR
Section 271(1)(c)Section 274

penalty was initiated for concealment of specified whether the penalty was initiated for concealment of specified whether the penalty was initiated for concealment of income or furnishing inaccurate particulars of income. We find that income or furnishing inaccurate particulars of income. We find that income or furnishing inaccurate particulars

J.P Tobaco Producta Pvt. Ltd vs. Asst. Commissioner of Income Tax Circle - Sagar

In the result, both the appeals filed by the assessee are In the result, both the appeals filed by the assessee are In the result, both the appeals filed by the assessee are allowed

ITA 187/JAB/2016[2002-03]Status: DisposedITAT Jabalpur20 Oct 2023AY 2002-03

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Ita Nos. 187 & 188/Jab/2016 Assessment Years: 2002-03 & 2003-04 J.P. Tobacco Products Pvt. Ltd., Acit Circle-Sagar. Pathariya Phatak, Damoh (M.P.) Vs. Pan No. Aaacj 7141 G Appellant Respondent Assessee By : Mr. G.N. Purohit, Sr. Advocate & Mr. Abhijeet Shrivastava, Advocate Revenue By : Mr. Saad Kidwai, Cit-Dr : Date Of Hearing 22/09/2023 Date Of Pronouncement : 20/10/2023

For Appellant: Mr. G.N. Purohit, Sr. Advocate &For Respondent: Mr. Saad Kidwai, CIT-DR
Section 271(1)(c)Section 274

penalty was initiated for concealment of specified whether the penalty was initiated for concealment of specified whether the penalty was initiated for concealment of income or furnishing inaccurate particulars of income. We find that income or furnishing inaccurate particulars of income. We find that income or furnishing inaccurate particulars

Vinay Parmanand Hariani, Mumbai vs. ITO (It), Ward-2(2)(1), Mumbai

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

ITA 985/MUM/2023[2015-16]Status: DisposedITAT Mumbai19 Oct 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Vinay Parmanand Hariani, Ito, Int. Taxation Ward 2(2)(1), Kempinski Private Residences Room No. 1725, 17Th Floor, Air Vs. Unit 40F Dki Jakarta, 10310 India Building, Nariman Point, Indonesia. Mumbai-400021. Pan No. Aabph 4179 A Appellant Respondent

For Appellant: Mr. Piyush ChaturvediFor Respondent: Mr. Anil Sant, Sr. DR
Section 115GSection 69A

also also also initiated initiated initiated separately for separately for separately for concealment of income. concealment of income.” 6.1 Before us, the Ld. Counsel of the as Before us, the Ld. Counsel of the assessee has submitted that sessee has submitted that this addition was not part of the draft

Yogendraraj U. Singhvi, Mumbai vs. Income Tax Officer, Ward-2(3)(8), Surat

In the result, appeal of the assessee is allowed

ITA 459/SRT/2023[2007-08]Status: HeardITAT Surat19 Oct 2023AY 2007-08

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.459/Srt/2023 (Ay 2007-08) (Hearing In Hybrid Mode) Yogendra Raj U Singhvi, Income Tax Officer-2(3)(8) Cts, 95/4/B-3-4/590, Aaykar Bhavan, Majura Gate, Vs Village Dindoshi, Surat-395001 Oberoi Garden City, Flat No. 3902, Floor C-Wing, Meter Exquisite, Mumbai. Pan : Anjps 9745 G अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 254(1)Section 271(1)(c)Section 274

validity of notice which was issued by assessing officer in a mechanical manner, without recording the satisfaction, if the notice was foe concealment of income or for furnishing inaccurate particulars of income. Thus, in absence of specific charge, the action of the assessing officer is vitiated and the order passed ... such notice submits that the assessing officer has not strike off the inappropriate portion of the notice, in specifying the charges either ‘for concealment of income’ or for ‘furnishing inaccurate particulars of such income’. The ld AR for the assessee submits that he has also filed copy of assessment order

Smt. Krishna, Alwar vs. ITO, Ward-Bhiwadi, Alwar

In the result, both appeal of the assessee in ITA No

ITA 435/JPR/2023[2010-11]Status: DisposedITAT Jaipur19 Oct 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (FCA.)For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 151(1)Section 271(1)(c)Section 69

penalty proceedings as also the penalty order is not specific as to the charge for which penalty is levied, i.e. whether for concealment of income or for furnishing inaccurate particulars of income. Hence, the penalty so levied is illegal & bad in law. For this purpose reliance is placed ... Trib.) It is incumbent upon the AO to specify whether the penalty u/s 271(1)(c) is being levied for concealment of income or for furnishing inaccurate particulars of income. In the absence of specific charge, levy of penalty would be bad in law. In the instant case, AO initiated

Smt. Krishna, Alwar vs. ITO, Ward-Bhiwadi, Alwar

In the result, both appeal of the assessee in ITA No

ITA 434/JPR/2023[2010-11]Status: DisposedITAT Jaipur19 Oct 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P. C. Parwal (FCA.)For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 151(1)Section 271(1)(c)Section 69

penalty proceedings as also the penalty order is not specific as to the charge for which penalty is levied, i.e. whether for concealment of income or for furnishing inaccurate particulars of income. Hence, the penalty so levied is illegal & bad in law. For this purpose reliance is placed ... Trib.) It is incumbent upon the AO to specify whether the penalty u/s 271(1)(c) is being levied for concealment of income or for furnishing inaccurate particulars of income. In the absence of specific charge, levy of penalty would be bad in law. In the instant case, AO initiated

Saimandeep Industries of India, Ghaziabad vs. AO-Ward-51(92), Faridabad

In the result, the appeal of the assessee is allowed

ITA 1372/DEL/2022[2012-13]Status: DisposedITAT Delhi18 Oct 2023AY 2012-13

Bench: Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Ms. Meenakshi Dohre, Sr.DR
Section 147Section 271(1)(c)

account of the parties, namely, Apex Associates and Supreme Enterprises. The Assessing Officer estimated 12% of the purchases as unexplained and accordingly alleged concealment of income at Rs.3,79,520/- on a total purchase of Rs.31,62,667/- from these parties. The penalty proceedings were invoked and 100% penalty

Mahanadi Coalfields Ltd., Burla, Sambalpur vs. DCIT Circle2(1), Sambalpur

In the result, appeal filed by the revenue being ITA No

ITA 41/CTK/2023[2020-21]Status: DisposedITAT Cuttack17 Oct 2023AY 2020-21

Bench: Shri George Mathan & Shri Girish Agrawalआयकर अऩीऱ सं/Ita Nos.14 To 17/Ctk/2023 & आयकर अऩीऱ सं/Ita No.41/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Mahanadi Coalfields Limited, Vs Acit/Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita Nos.70 To 73/Ctk/2023 & आयकर अऩीऱ सं/Ita No.147/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita No.69/Ctk/2023 (ननधाारण वषा / Assessment Year : 2015-2016) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.S.Poddar, Ca राजस्व की ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/10/2023 घोषणा की तारीख/Date Of Pronouncement : 17/10/2023 आदेश / O R D E R Per Bench :

For Appellant: Shri S.S.Poddar, CAFor Respondent: Dr. Abani Kanta Nayak, CIT-DR
Section 271(1)(c)

account of various disallowance made in the assessment order for the assessment year 2015-2016. It was the submission that there was concealment of income insofar as the addition in respect of the disallowance u/s.14A of the Act had also been confirmed by the ld. CIT(A) in appeal ... proposed by the AO remained and even the disallowance u/s.14A of the Act was only a deemed disallowance and it was not a concealment of income. It was the submission that the ld. CIT(A) had considered these issues and had followed the principle laid down

Mahanadi Coalfields Ltd., Burla, Sambalpur vs. DCIT Circle2(1), Sambalpur

In the result, appeal filed by the revenue being ITA No

ITA 14/CTK/2023[2016-17]Status: DisposedITAT Cuttack17 Oct 2023AY 2016-17

Bench: Shri George Mathan & Shri Girish Agrawalआयकर अऩीऱ सं/Ita Nos.14 To 17/Ctk/2023 & आयकर अऩीऱ सं/Ita No.41/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Mahanadi Coalfields Limited, Vs Acit/Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita Nos.70 To 73/Ctk/2023 & आयकर अऩीऱ सं/Ita No.147/Ctk/2023 (ननधाारण वषा / Assessment Years : 2016-2017 To 2020-2021) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P & आयकर अऩीऱ सं/Ita No.69/Ctk/2023 (ननधाारण वषा / Assessment Year : 2015-2016) Acit/Dcit, Circle-2(1), Sambalpur Vs Mahanadi Coalfields Limited, Jagriti Vihar, Burla, Sambalpur-768020 Pan No. :Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.S.Poddar, Ca राजस्व की ओर से /Revenue By : Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/10/2023 घोषणा की तारीख/Date Of Pronouncement : 17/10/2023 आदेश / O R D E R Per Bench :

For Appellant: Shri S.S.Poddar, CAFor Respondent: Dr. Abani Kanta Nayak, CIT-DR
Section 271(1)(c)

account of various disallowance made in the assessment order for the assessment year 2015-2016. It was the submission that there was concealment of income insofar as the addition in respect of the disallowance u/s.14A of the Act had also been confirmed by the ld. CIT(A) in appeal ... proposed by the AO remained and even the disallowance u/s.14A of the Act was only a deemed disallowance and it was not a concealment of income. It was the submission that the ld. CIT(A) had considered these issues and had followed the principle laid down

Manoj Mittal, New Delhi vs. DCIT Central Circle-8, New Delhi

In the result, appeal of the assessee is allowed

ITA 2412/DEL/2023[2010-11]Status: DisposedITAT Delhi16 Oct 2023AY 2010-11

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.2412/Del/2023 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Manoj Mittal, Dcit H-1, Phase-1, Ashok Vihar, Vs. Central Circle-8, New Delhi. New Delhi. Pan No. Aaipm7274J अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 2(22)(e)Section 254Section 271(1)(c)

without considering the fact that Explanation 1 of Section 271(1)(c) of Act can be invoked only if there is concealment of income, while in the case of appellant the Ld. AO himself imposed penalty for furnishing of inaccurate particulars of income. Thus, imposing of penalty by mechanically invoking ... analyze the relevant provision u/s 271(1)(c) Explanation 1, which is reproduced herein below: Failure to furnish returns, comply with notices, concealment of income, etc. “271. (1) If the Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner in the course of any proceedings under this

Anand Kumar Jain, New Delhi vs. JCIT (OSD), Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1322/DEL/2023[2015-16]Status: DisposedITAT Delhi12 Oct 2023AY 2015-16

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts

Anand Kumar Jain, New Delhi vs. JCIT (OSD), Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1321/DEL/2023[2014-15]Status: DisposedITAT Delhi12 Oct 2023AY 2014-15

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts

Anand Kumar Jain, New Delhi vs. JCIT (OSD), Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1320/DEL/2023[2013-14]Status: DisposedITAT Delhi12 Oct 2023AY 2013-14

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts

Anand Kumar Jain, New Delhi vs. JCIT (OSD), Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1319/DEL/2023[2012-13]Status: DisposedITAT Delhi12 Oct 2023AY 2012-13

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts

Anand Kumar Jain, New Delhi vs. JCIT (OSD), Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1318/DEL/2023[2011-12]Status: DisposedITAT Delhi12 Oct 2023AY 2011-12

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts

Anand Kumar Jain, New Delhi vs. JCIT (OSD) Central Circle-26, New Delhi

In the result, the appeals of the assessee are allowed

ITA 1317/DEL/2023[2010-11]Status: DisposedITAT Delhi12 Oct 2023AY 2010-11

Bench: Shri G.S Pannu, Hon’Ble & Shri Chandra Mohan Garg

For Appellant: Shri Ved Jain, Adv
Section 271Section 271(1)(c)Section 274Section 68

levied by the AO rejecting the contention of the assessee that penalty was levied without giving finding on merits of the case as concealment of income as well as furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred ... both on facts and in law in levying penalty despite the fact that there is neither concealment of income nor furnishing the inaccurate particulars of income by the assessee. 10. On the facts and circumstances of the case, learned CIT (A) has erred, both on facts