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“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

Virender Singh, Advocate, Asalatpur vs. ITO, Ward 2(2)(5), Ghaziabad

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

ITA 1126/DEL/2023[2012-13]Status: DisposedITAT Delhi11 Sept 2023AY 2012-13

Bench: Shri C.M. Garg & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Dinesh Kumar, AdvFor Respondent: Shri Anuj Garg –SR. DR
Section 144Section 271(1)(c)Section 69

which is pending for disposal as on date. 4. Consequent to this addition, penalty proceedings under Section 271(1)(c) was initiated for concealment of income. Penalty order was passed on 31.12.2021 imposing a penalty of Rs.1,93,331. Assessee filed the appeal against this penalty order before the learned

Bahar Ahmed, Bijnor vs. ACIT, Najibabad

In the result, the appeal of the assessee is allowed

ITA 1004/DEL/2023[2014-15]Status: DisposedITAT Delhi11 Sept 2023AY 2014-15

Bench: Shri N.K. Billaiya & Shri Kul Bharat[A.Y. 2014-15]

For Appellant: Shri PC Yadav, AdvocateFor Respondent: Shri Kanav Bali, Sr. DR
Section 143Section 271Section 274

penalty proceedings were separately initiated for furnishing inaccurate particulars of income. 5. The penalty was levied at Rs.2254422/- vide order dated 25.09.2019 for concealment of income. 6. The notice issued u/s. 274 dated 29.12.2016 reads as under :- 4 7. It can be seen that the additions were made ... satisfaction drawn was for furnishing inaccurate particulars of income the penalty was levied for concealment of income and the notice is completely silent in respect of under which limb of the relevant provision the penalty is to be levied. The Hon’ble High Court of Delhi in the case

Shivom Vidyapeeth Shikshan Samiti, Raipur vs. Income Tax Officer, Exemetion 2, Raipur

In the result, the appeal of the assessee is allowed

ITA 261/RPR/2022[2015-16]Status: DisposedITAT Raipur06 Sept 2023AY 2015-16

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.261/Rpr/2022 "नधा"रण वष" /Assessment Year: 2015-16 Shivom Vidyapeeth Shikshan Samiti V Income Tax Officer 214, Shivom Vihar Raipur-492 013 S Exemption-2 Chhattisgarh Raipur Pan: Aahts 6464M (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri G.S. Agrawal & Shubham Agarwal, Cas राज"व क" ओर से /Revenue By : Shri Satya Prakash Sharma, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 08/08/2023 घोषणा क" तार"ख/Date Of Pronouncement : 06/09/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Captioned Appeal Is Filed By The Assessee Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 26.10.2022 U/S 250 Of The Income Tax Act, 1961 For Ay 2015-16, Instituted Against The Penalty Order By Ld. Assessing Officer U/S 271(1)(C) Dated 28.06.2018. The Grounds Of The Appeal Raised By The Assessee Are As Under: “1. That Under The Facts & The Law, The Ld. Cit (A) Erred In Confirming The Order Of Penalty Levied By The Ld. Ao U/S 271(1)(C) At Rs.2,40,630/- Rejecting The Explanation. Prayed That Provisions Of Sec.271(1)(C) Are Not Applicable, Penalty Levied At Rs.2,40,630/- Kindly Be Cancelled. 2. That Under The Facts & The Law, The Ld. Cit (A) Further Erred In Confirming The Penalty Levied At Rs. 2,40,630/- U/S 271(1)(C) By The Ld. Ao, Though The Ld. Ao Did Not Allow Opportunity To The Appellant As To For Which Default, Penalty Proceedings Were Initiated. Prayed To Cancel The Penalty.

For Appellant: Shri G.S. Agrawal & ShubhamFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 10Section 11Section 12ASection 143(3)Section 250Section 271(1)(c)Section 57

return of income. Accordingly, the AO levied penalty u/s 271(1)(c) on the addition of Rs.11,47,592/- considering the concealment of income by the assessee. 4. Aggrieved by the order of Assessing Officer, the assessee preferred an appeal before the Ld. CIT(A), NFAC. However, the contentions

Arun Soni, Bilaspur vs. Income Tax Officer-1(1), Bilaspur

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

ITA 221/RPR/2023[2012-13]Status: DisposedITAT Raipur05 Sept 2023AY 2012-13

Bench: Shri Ravish Soodआयकर अपील सं. / Ita Nos. 220 & 221/Rpr/2023 "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 Arun Soni Industrial Area, Tifra Bilaspur (C.G.)-495 001 Pan: Ajeps8535K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Nilesh Jain, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 147Section 148Section 151

Rs.22,27,200/- is added to the total income as undisclosed investment. Penalty proceedings u/s.271(1)(c) is initiated for concealment of income separately.” The A.O on the basis of his aforesaid deliberations, vide his order passed u/ss.143(3)/147 of the Act dated 18.12.2018 after making an addition

Arun Soni, Bilaspur vs. Income Tax Officer-1(1), Bilaspur

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

ITA 220/RPR/2023[2011-12]Status: DisposedITAT Raipur05 Sept 2023AY 2011-12

Bench: Shri Ravish Soodआयकर अपील सं. / Ita Nos. 220 & 221/Rpr/2023 "नधा"रण वष" / Assessment Years : 2011-12 & 2012-13 Arun Soni Industrial Area, Tifra Bilaspur (C.G.)-495 001 Pan: Ajeps8535K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Nilesh Jain, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 147Section 148Section 151

Rs.22,27,200/- is added to the total income as undisclosed investment. Penalty proceedings u/s.271(1)(c) is initiated for concealment of income separately.” The A.O on the basis of his aforesaid deliberations, vide his order passed u/ss.143(3)/147 of the Act dated 18.12.2018 after making an addition

Ashok Kumar Singh, Durg vs. Income Tax Officer-2(2), Bhilai, Durg

In the result, the assessee's appeal is allowed in terms of our observations above

ITA 150/RPR/2023[2010-11]Status: DisposedITAT Raipur04 Sept 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 150/Rpr/2023 "नधा"रण वष" / Assessment Year : 2010-11 Ashok Kumar Singh P-10, Rishab Green City, Pulgaon, Durg-491 001 (C.G) Pan : Bcfps1394K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(2), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 147Section 148Section 271(1)(c)Section 274

while framing the assessment vide his order passed u/s.143(3) r.w.s. 147, dated 28.12.2017, had initiated the penalty proceedings u/s.271(1)(c) for concealment of income, but the usage of the term “OR” as a conjunction between the two defaults, i.e. “concealed the particulars of your income or furnished inaccurate ... penalty u/s.271(1)(c) may not be imposed on him. As the A.O in the aforesaid SCN had mentioned both the defaults, i.e., “concealment of income” or “furnishing of inaccurate particulars of income”, therefore, by using “OR” as a conjunction between both the defaults mentioned above, he had not only

Raj Kishore Prasad, Ahmedabad vs. Income Tax Officer, Ward - 3, Valsad

In the result, appeal filed by the assessee is allowed

ITA 146/SRT/2023[2012-13]Status: DisposedITAT Surat04 Sept 2023AY 2012-13

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.146/Srt/2023 Assessment Year: (2012-13) (Virtual Hearing) Raj Kishore Prasad, Vs. The Ito, 201, 2Nd Floor, Devashish Complex, Ward-3, Nr. Regenta Central Antarim Hotel, Valsad Off Cg Road, Ahmedabad "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aitpp0535A (Assessee) (Respondent)

Section 10(5)Section 144Section 147Section 271(1)(c)

proceedings, under section 271(1)(c) of the Act, the assessing officer has levied the penalty on both the limbs, that is, (i) concealment of income as well as (ii) furnishing of inaccurate particulars of income. Therefore, ld Counsel contended that there is an inconsistency in the charge levied ... under. “4. Considering the facts and circumstances and in view of the above discussion, I am satisfied to hold that the assessee has concealed his income by furnishing inaccurate particulars of income and therefore I am satisfied that this is a fit case for levy of penalty u/s.271

Mr Gaurav Ajmera, Ratlam vs. DCIT Central Circle -2, Indore

Accordingly. Thus, this ground is allowed partly for statistical purpose

ITA 71/IND/2022[2017-18]Status: DisposedITAT Indore01 Sept 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Mr. Gaurav Ajmera, Dcit, बनाम/ 38, Ram Mohalla, Central Circle 2, Ratlam Indore. Vs. (Assessee / Appellant) (Revenue / Respondent) Pan: Aglpa8863C Assessee By Shri Pawan Ved, Advocate & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 01.09.2023

Section 115BSection 131Section 132(4)Section 132ASection 143(3)Section 153ASection 153DSection 234ASection 271A

credit to the appellant/ assessee, as claimed. As a consequence of this finding, the appellate authority concluded that there was neither any concealment of income nor furnishing of inaccurate particulars of income by the assessee. We are conscious of the fact that these observations are made by the competent forum ... only accepted the explanation offered by the appellant/assessee but also recorded a clear finding of fact that there was no concealment of income or furnishing of any inaccurate particulars of income by the appellant/assessee for the assessment year 1998-1999. That now being the indisputable position, it must necessarily follow

Cobol Technologies Pvt. Ltd., New Delhi vs. ACIT Central Circle-18, Delhi

In the result, the appeal of the assessee is allowed

ITA 698/DEL/2023[2014-15]Status: DisposedITAT Delhi31 Aug 2023AY 2014-15

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: NoneFor Respondent: Sh. Vivek Kr. Upadhyay, Sr. DR
Section 271Section 271(1)(c)Section 274Section 68

notice under section 274 should specifically state the grounds mentioned in section 271(1)(c) of the Act, i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where all the grounds mentioned in section 271 are mentioned would not satisfy ... Court, since the AO has not been specified u/s 274 as to whether penalty is proposed for alleged 3 Cobol Technologies Pvt. Ltd. ‘concealment of income’ OR ‘furnishing of inaccurate particulars of such income’, the penalty levied is hereby obliterated. 6. In the result, the appeal of the assessee

ACIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, Gurgaon

In the result, all the appeals of the Revenue for the

ITA 441/DEL/2023[2007-08]Status: DisposedITAT Delhi31 Aug 2023AY 2007-08

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle 3(1)(1), International Taxation, New Delhi vs. Raytheon Company, United State

In the result, all the appeals of the Revenue for the

ITA 1392/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Aug 2023AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle 3(1)(1), International Taxation, New Delhi vs. Raytheon Company, United State

In the result, all the appeals of the Revenue for the

ITA 1391/DEL/2023[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1390/DEL/2023[2014-15]Status: DisposedITAT Delhi31 Aug 2023AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1389/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Aug 2023AY 2011-12

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1) Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1388/DEL/2023[2010-11]Status: DisposedITAT Delhi31 Aug 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1387/DEL/2023[2009-10]Status: DisposedITAT Delhi31 Aug 2023AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1) Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1386/DEL/2023[2008-09]Status: DisposedITAT Delhi31 Aug 2023AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1385/DEL/2023[2006-07]Status: DisposedITAT Delhi31 Aug 2023AY 2006-07

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int.Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1384/DEL/2023[2005-06]Status: DisposedITAT Delhi31 Aug 2023AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused

DCIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, United States

In the result, all the appeals of the Revenue for the

ITA 1383/DEL/2023[2004-05]Status: DisposedITAT Delhi31 Aug 2023AY 2004-05

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

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

were dismissed. Consequent to MAP proceedings final orders were passed and the penalties were levied u/s 271(1)(c) of the Act for concealment of income against which the assessee preferred appeals before the Ld.CIT(A) and the Ld.CIT(A) deleted the penalty on the ground that the quantum additions ... that there exists PE in India for assessee. Therefore, the Ld. Counsel for M/s Raytheon Company the assessee submits that there is no concealment of income or furnishing all inaccurate particulars by the assessee which warrant any penalty u/s 271(1)(c) of the Act. 4. Heard rival submissions, perused