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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

Venkatesh Raghav Rao Hebbani, New Delhi vs. Income Tax Officer Ward 34(5), New Delhi

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

ITA 474/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Shubham Jain, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 194ISection 271(1)(C)Section 271(1)(c)

appreciate that non-filing of the return of income within the due date under Section 139(1) does not automatically amount to concealment of income or furnishing of inaccurate particulars, as defined under Section 271(1)(c). 3. Bonafide Explanation Ignored: The learned CIT(A) overlooked the reasonable cause provided ... that the assessee is a salaried employee and on issuance of notice, assessee filed return of income and declared the income and not concealed any income and prayed that the penalty may be deleted. 7. On the other hand, ld. DR of the Revenue relied on the findings

Zenith Portfolio and Insurance Advisors (P) Ltd, Delhi vs. DCIT, Central Circle-3, Delhi

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

ITA 2223/DEL/2024[2018-19]Status: DisposedITAT Delhi26 Sept 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Sanjeev Kaushal, CIT DR
Section 115BSection 132Section 133DSection 153ASection 153CSection 234BSection 37Section 68

undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income.” 12. Respectfully following the above decision, we are inclined to come to a conclusion that satisfaction note recorded by the AO is vague

Zenith Portfolio and Insurance Advisors (P) Ltd, Delhi vs. DCIT, Central Circle-3, Delhi

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

ITA 2222/DEL/2024[2017-18]Status: DisposedITAT Delhi26 Sept 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Sanjeev Kaushal, CIT DR
Section 115BSection 132Section 133DSection 153ASection 153CSection 234BSection 37Section 68

undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income.” 12. Respectfully following the above decision, we are inclined to come to a conclusion that satisfaction note recorded by the AO is vague

Zenith Portfolio and Insurance Advisors (P) Ltd, Delhi vs. DCIT, Central Circle-3, Delhi

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

ITA 2221/DEL/2024[2016-17]Status: DisposedITAT Delhi26 Sept 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Sanjeev Kaushal, CIT DR
Section 115BSection 132Section 133DSection 153ASection 153CSection 234BSection 37Section 68

undisclosed income to the tune of Rs. 33 crores has been detected in the case of M/s Olympus Realtors (P) Ltd. resulting into concealment of income.” 12. Respectfully following the above decision, we are inclined to come to a conclusion that satisfaction note recorded by the AO is vague

Kamuben Ramanlal Patel, Daman vs. Income Tax Officer, Daman

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

ITA 913/SRT/2024[2012-13]Status: DisposedITAT Surat25 Sept 2025AY 2012-13

Bench: Ms.Suchitra Raghunath Kamble& Shri Bijayananda Prusethआयकरअपीलसं./Ita No.913/Srt/2024 Assessment Year: 2012-13 (Hybrid Hearing) Smt. Kamuben Ramanlal Patel Income Tax Officer, Daman, बनाम/ House No.1, Varkund, Income Tax Department, Jeevanji Vs. Mithanagar, Nani Daman, Hotel Building, Kathiria Road, Daman & Diu-396 210 Nani Daman, Daman & Diu- -396210 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acppk1885N (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri Hemant Suthar, Ca राज"कीओरसे /Respondent By Shriajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 17/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 25/09/2025

Section 143(3)Section 250Section 271(1)Section 271(1)(c)Section 274

notice proposing the penalty as required u/s.274 has not specified the charge for the levy of penalty as to for concealment of income or for furnishing inaccurate particulars. Moreover, Ld. AO has levied penalty on dual charges of concealment of income and furnishing of inaccurate particulars of income against ... account of LTCG and raising demand of Rs.2,24,80,170/-. Along with this, the AO also initiated penalty proceedings for concealment of income and furnishing inaccurate particulars of income u/s.271(1)(c) of the Act. The assessee had filed an appeal before the CIT(A) against the impugned assessment

Kartik Clothing & Fabrics Private Limited, Ahmedabad vs. Deputy Commissioner of Income Tax, Circle 2(1)(1), Ahmedabad

In the result, the appeal of the assessee is accordingly allowed

ITA 119/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Sept 2025AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Hargovind Singh, Sr. DR
Section 132Section 133(6)Section 143(1)Section 144BSection 147Section 69A

assessed income for A.Y. 2018-19 was computed at ₹1,52,30,465/-, and penalty proceedings under section 271AAC were also initiated for concealment of income. 4. In appeal, CIT(Appeals) dismissed the appeal of the assessee. The assessee had challenged the reopening of assessment under Section

Conwood Construction and Developers Private Limited, Mumbai vs. DCIT Central Circle - 1(4), Mumbai

ITA 4756/MUM/2025[2015-16]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 254(1)Section 270(1)Section 271(1)(c)Section 274

course of assessment proceedings whether the levy of penalty u/s 271(1)(c) was for furnishing inaccurate particulars of income or for concealment of income, which constitutes the basis and foundation of the proceedings for levy of penalty, thereby making the notice dated 19.12.2017 levying penalty u/s 274 r.w.s ... which penalty was sought to be imposed, i.e., notice did not indicate as to whether penalty was to be levied on account of concealment of income or for reason that assessee had furnished inaccurate particulars quashed the penalty proceedings and High Court, on appeal, concluded that no substantial question

Assistant Commissioner of Income Ta, Jaipur vs. Shri Nath Corporation, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

Rs.1,34,14,976/- u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,94,67,426/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.2 In ITA No. 196/JPR/2024 ... Rs.94,83,138/-u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,16,10,463/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.3 In ITA No. 197/JPR/2024, the Revenue

Assistant Commissioner of Income Tax, Jaipur vs. Jitendra Kumar Agarwal, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

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

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a
Section 133ASection 271(1)(c)

Rs.1,34,14,976/- u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,94,67,426/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.2 In ITA No. 196/JPR/2024 ... Rs.94,83,138/-u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,16,10,463/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.3 In ITA No. 197/JPR/2024, the Revenue

Assistant Commissioner of Income-Tax, Jaipur vs. Royal Jewellers, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

Rs.1,34,14,976/- u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,94,67,426/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.2 In ITA No. 196/JPR/2024 ... Rs.94,83,138/-u/s 271(1)(c) of the Income Tax Act, 1961 ignoring the fact that the penalty was levied for concealing the income of Rs.3,16,10,463/- which was detected during the survey proceedings u/s 133A of the I.T. Act?" 3.3 In ITA No. 197/JPR/2024, the Revenue

Ashok Gurunath Patil, Latur vs. ITO Ward1(1), Latur

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

ITA 594/PUN/2025[2011-12]Status: DisposedITAT Pune24 Sept 2025AY 2011-12

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.594/Pun/2025 धििेंारण वर्ा /Assessment Year: 2011-2012 Ashok Gurunath Patil, Ito, Ward 1(1), Latur A/P Masobavadi, Khed, Nilanga, Latur-413522 Vs. Maharashtra Pan-Bihpp0618K अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Pratik Sandbhor Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 21.08.2024 Which Is Arising Out Of Order Passed U/S 271(1)(C) Of The Act Dated 27.02.2018. 2. Registry Has Informed That There Is A Delay Of 123 Days In Filing Of The Appeal. Application For Condonation Of Delay Alongwith Affidavit Has Been Filed & Placed At Page No. 24-26 Of The Appeal Citing The Main Reason For The Delay, That The Assessee Was Not Aware Of Passing Of The Impugned Order As 2 The Tax Consultant Registered The E-Mail Id Of His Younger Son & The E-Mail Account Was Not In Use. After Hearing The Ld. Departmental Representative (Dr) & Perusing The Records We Find That The Sufficient Cause Prevented The Assessee From Filing The Appeal Within The Prescribed Time Limit & The Delay Is Not Intentional. Therefore In The Larger Interest Of Justice & Also Placing Reliance On The Judgement Of Hon’Ble Apex Court In The Case Of Collector, Land Acquisition Vs. Master Katiji & Others(1987) 167 Itr 471(Sc) (Supreme Court) & In The Case Of Inder Singh Vs State Of Madhya Pradesh Judgement Dated 21.03.2025 (2025) Insc 382) We Hereby Condone The Delay Of 123 Days & Admit The Appeal For Adjudication On Merits.

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Ramnath P Murkunde
Section 250Section 271(1)(c)Section 274

penalty order u/s 271(1)(c) is invalid and bad in law in as much as the penalty has been initiated for concealment of income whereas the penalty has been levied for furnishing inaccurate particulars of income 4. On the facts and in the circumstances of the case

ITO, Delhi vs. Usha Rani, Delhi

Appeal are allowed

ITA 2286/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Sept 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2016-17 Ito, Vs Usha Rani, Ward-44(1), 593, Rani Bagh, Delhi. Delhi. Pan: Ahrpc1449F (Appellant) (Respondent) Assessee By : Shri Sanjay Gupta, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 08.09.2025 Date Of Pronouncement : 24.09.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 07.02.2025 Of The Commissioner Of Income-Tax (Appeals), Nfac, Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeal No.Nfac/2015-16/10332913 Arising Out Of The Appeal Before It Against The Order Dated 08.03.2024 Passed U/S 147 R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Ito, Ward-44(1), Delhi (Hereinafter Referred To As The Ld. Ao). 2. On Hearing Both The Sides, We Find That The Case Of The Revenue Is That The Assessee Has Been Erroneously Benefitted By The Ld.Cit(A) As The Source Of The Source Of Her Husband’S Agricultural Activities Has Not Been Examined. We Find That The Revenue Has Also Raised A Ground That Additional Evidences Were Accepted Without Giving The Ao An Opportunity To Contest.

For Appellant: Shri Sanjay Gupta, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(2)Section 147Section 148Section 148ASection 69

unexplained investment u/s.69 and added to the total income of the assesseeand initiated penalty proceedings u/s.271(1)(c) of the Act for concealment of income and also initiated penalty u/s.271F for non-filing of return of income. 7.2 Ground nos 1, 2 and 6 are against initiation of re-assessment

Jayeshkumar Baldevbhai Patel, Ahmedabad vs. The Income Tax Officer, Ward-4(2)(2), Ahmedabad

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

ITA 595/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad23 Sept 2025AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 147Section 148Section 250

which was added to the total income of the assessee. Penalty proceedings under section 271(1)(c) were also initiated for concealment of income. 4. In the appeal filed by the assessee before the CIT(Appeals), after reviewing the facts and legal position, CIT(Appeals) upheld the action

Allied Construction Company, Malad vs. Income Tax Officer - 30 (1) (1), Bandra

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

ITA 4121/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2012-13 M/S. Allied Construction Ito-30(1)(1), Company, C-13, 5Th Floor, 4&5, Sai Zarukha Vs. Pratyakshakar Bhavan, B.J. Patel Road, Bandra East, Malad (West), Mumbai-400051. Mumbai-400064. Pan : Aapfa8255N (Appellant) (Respondent) Assessee By : Shri Jose Pulikkoden Revenue By : Shri Surendra Mohan, Sr.Dr

For Appellant: Shri Jose PulikkodenFor Respondent: Shri Surendra Mohan, Sr.DR
Section 133ASection 271(1)(c)

appearing in the books of accounts of the Appellant was to be offered to tax, thereby proving that there is no deliberate concealment of income nor furnishing of inaccurate particulars thereof by the Appellant. 7. That the Ld. CIT(A) has erred in concluding that the Appellant failed to discharge ... Separately, the penalty proceedings u/s. 271(1)(c) of the Act 4 were initiated for filing the inaccurate particulars and concealing of income and notice u/s. 271(1)(c) r.w.s. 274 of the Act was issued on 16-03-2015. 3. The assessee thereafter carried the matter in appeal before

Gajanand Financial Consultancy Private Limited, Nagpur vs. Principal Commissioner of Income Tax (Central) Nagpur, Nagpur

In the result, assessee’s appeal is allowed

ITA 126/NAG/2025[2013-2014]Status: DisposedITAT Nagpur22 Sept 2025AY 2013-2014

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Pankaj Kumar
Section 143(3)Section 263Section 68

u/s.68 of the IT Act. Penalty proceedings u/s 271(1)(c) of the Act is hereby Initiated separately for concealment of income.. 8.1 Hence, in order to protect the interest of the revenue, the addition of Rs.14,10,00,000/- is made in the case of the Assessee

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2006/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

original return. 5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2005/DEL/2025[2015-16]Status: DisposedITAT Delhi22 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

original return. 5. Initiation of Penalty Proceedings Under Section 271(1)(c) is Premature o The initiation of penalty proceedings for alleged concealment of income is premature and without proper justification. PRAYER: The appellant respectfully prays that:  The addition of ₹1,54,00,000/- as undisclosed short-term capital gain

Megnanapuram Paccs, Tiruchendur vs. PCIT, Madurai

ITA 895/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Sept 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:895/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Megnanapuram Primary Agricultural Co-Operative Credit Society 4/40, Megnanapuram Tiruchendur Road, Tiruchendur Thoothukudi – 628 210. [Pan: Aabam-9847-M] (अपीलार्थी/Appellant) Pcit Vs. Madurai - I (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 24.06.2025 घोषणा की तारीख/Date Of Pronouncement : 19.09.2025 आदेश /Order Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Pcit, Madurai - 1, For The Assessment Year 2018-19, Vide Order Dated 17.03.2025. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 147Section 148Section 263Section 80P

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Krishna Enterprises, Delhi vs. ACIT Circle 34(1), Delhi

In the result, appeal of the assessee is allowed

ITA 5654/DEL/2024[2013-14]Status: DisposedITAT Delhi19 Sept 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] Krishna Enterprises, Assistant Commissioner Of 202, Bhagirathi Apartment, Income Tax, Sector-9, Rohini, Delhi- Vs Circle 34(1), 110085. Delhi. Pan- Aahfk4892P Assessee Revenue

Section 148Section 271(1)(c)Section 271BSection 44A

levied depending upon the merits of the quantum additions made in the assessment order with specific emphasis on whether there was any concealment of income or whether there was any furnishing of inaccurate particulars. Therefore, the courts have held that the specific limb as to whether the penalty notice ... 5654/Del/2024 Krishna Enterprises was issued for concealment of income or whether it was issued for furnishing of inaccurate particulars needs to be ticked/struck off as the case may be. But, the issue under discussion in the instant case of the appellant is one of a procedural penalty u/s 271B. Penalties

Dialnet Communications Ltd., New Delhi vs. ITO Ward - 7(3), New Delhi

In the result the appeal of the assessee is allowed

ITA 7885/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2015-16 Dial Net Communications Ltd., Vs Income Tax Officer, C-31, Ground Floor, Greater Ward-7(3), New Delhi. Kailash, Part-I, Delhi-110048. Pan: Aabcd 5472 D Appellant Respondent

Section 271(1)Section 271(1)(c)Section 274

defective in as much as it did not specifically clarify as to whether the penalty was being proposed to be imposed for concealment of income or for furnishing of inaccurate particulars. The Ld.Counsel for the assessee argued that it is settled principle of law that the Ld.AO in its notice ... must vividly indicate as to whether the penalty was being proposed to be imposed for concealment of income or for furnishing of inaccurate particulars. It was argued that in the absence thereof the penalty notice per se would become infructuous and invalid and that therefore no consequent penalty order