concealment of income — 2,901 case laws

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 578/HYD/2025[2013-2014]Status: DisposedITAT Hyderabad28 Aug 2025AY 2013-2014

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

For Appellant: Shri K C Devdas, C.AFor Respondent: : Dr. Narendra Kumar Naik

Section 132Section 133ASection 144Section 269SSection 271(1)(c)Section 271DSection 68

without considering that the learned Assessing Officer (‘AO’) has also initiated penalty proceedings under Section 271(1)(c) of the Act for alleged concealment of income on the same amount, thereby subjecting the appellant to double jeopardy, which is contrary to settled legal principles and in gross violation ... initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the assessment proceedings regarding the concealment of income which would constitute the basis and foundation of the proceedings for levy of penalty". 6.9 The reliance of the Panel Counsel on CBDT Circular

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 577/HYD/2025[2010-2011]Status: DisposedITAT Hyderabad28 Aug 2025AY 2010-2011

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

For Appellant: Shri K C Devdas, C.AFor Respondent: : Dr. Narendra Kumar Naik

Section 132Section 133ASection 144Section 269SSection 271(1)(c)Section 271DSection 68

without considering that the learned Assessing Officer (‘AO’) has also initiated penalty proceedings under Section 271(1)(c) of the Act for alleged concealment of income on the same amount, thereby subjecting the appellant to double jeopardy, which is contrary to settled legal principles and in gross violation ... initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the assessment proceedings regarding the concealment of income which would constitute the basis and foundation of the proceedings for levy of penalty". 6.9 The reliance of the Panel Counsel on CBDT Circular

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 576/HYD/2025[2010-2011]Status: DisposedITAT Hyderabad28 Aug 2025AY 2010-2011

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

For Appellant: Shri K C Devdas, C.AFor Respondent: : Dr. Narendra Kumar Naik

Section 132Section 133ASection 144Section 269SSection 271(1)(c)Section 271DSection 68

without considering that the learned Assessing Officer (‘AO’) has also initiated penalty proceedings under Section 271(1)(c) of the Act for alleged concealment of income on the same amount, thereby subjecting the appellant to double jeopardy, which is contrary to settled legal principles and in gross violation ... initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the assessment proceedings regarding the concealment of income which would constitute the basis and foundation of the proceedings for levy of penalty". 6.9 The reliance of the Panel Counsel on CBDT Circular

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 575/HYD/2025[2009-10]Status: DisposedITAT Hyderabad28 Aug 2025AY 2009-10

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.575 To 578/Hyd/2025 (निर्धारण वर्ा/Assessment Years:2009-10, 2010-11 & 2013-14) Shri Balreddy Gade, Addl. Commissioner Of Income Tax, Vs. Hyderabad. Central Range-1, Pan:Adepg7858D Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri K C Devdas, C.A. रधजस् व द्वधरध/Revenue By:: Dr. Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 07/08/2025 घोर्णध की तधरीख/Pronouncement: 28/08/2025 आदेश/Order Per Bench :

For Appellant: Shri K C Devdas, C.AFor Respondent: : Dr. Narendra Kumar Naik

Section 132Section 133ASection 144Section 269SSection 271(1)(c)Section 271DSection 68

without considering that the learned Assessing Officer (‘AO’) has also initiated penalty proceedings under Section 271(1)(c) of the Act for alleged concealment of income on the same amount, thereby subjecting the appellant to double jeopardy, which is contrary to settled legal principles and in gross violation ... initiating the proceedings. It would, indeed, be the satisfaction of the Income Tax Officer in the course of the assessment proceedings regarding the concealment of income which would constitute the basis and foundation of the proceedings for levy of penalty". 6.9 The reliance of the Panel Counsel on CBDT Circular

Ranjit Pathak, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 4102/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey () & Shri Om Prakash Kant ()

For Respondent: Mr. Bharat Kumar

Section 142(1)Section 144Section 147Section 148Section 251Section 251(1)(a)Section 271(1)Section 271(1)(b)Section 271(1)(c)

made an addition of Rs.55,97,095/- and initiated penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The ld AO also initiated penalty u/s 271(1)b) of the Act for non-compliance of the notices issued u/s 142(1) of the Act dated

Ranjit Pathak, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 4101/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey () & Shri Om Prakash Kant ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Krishna Kumar, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 251Section 251(1)(a)Section 271(1)Section 271(1)(b)Section 271(1)(c)

made an addition of Rs.55,97,095/- and initiated penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The ld AO also initiated penalty u/s 271(1)b) of the Act for non-compliance of the notices issued u/s 142(1) of the Act dated

Chromex, Mumbai vs. DCIT -17(1), Mumbai

In the result, the appeal of the assessee is In the result, the appeal of the assessee is dismissed dismissed

ITA 3793/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Aug 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2014-15 Chromex, Dcit-17(1), 406, Konarkshram, 156, Pmm Kautilya Bhavan, Bkc, Bandra Vs. Road, Tardeo, West, Mumbai-400034. Mumbai. Pan No. Aabfc 4027 G Appellant Respondent

For Appellant: Mr. Asif Karmali, Sr. DRFor Respondent: Ms. Ridhisha Jain, CA

Section 133(6)Section 35(1)(ii)

appellant to evade tax adjustment entry availed by the appellant to evade tax adjustment entry availed by the appellant to evade tax and concealment of income as pointed out by the AO in his order. and concealment of income as pointed out by the AO in his order. and concealment

Jsl Media Ltd, New Delhi vs. ACIT, Circle-13(2), New Delhi

Accordingly, the appeal in ITA No.9650/Del/2019 of the assessee is allowed

ITA 9650/DEL/2019[2012-13]Status: DisposedITAT Delhi28 Aug 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year: 2012-13 Assessment Year : 2012-13 Jsl Media Limited, Vs Dcit, 28, Najafgarh Road, Circle-13(1), New Delhi – 110 015. New Delhi. Pan: Aaecp5027F (Appellant) (Respondent) Assessee By : Shri Satya Jeet Goel, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 28.08.2025 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Dated 15.12.2016 & 21.10.2019 Of The Commissioner Of Income-Tax (Appeals)-5, Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals No.Del/Cit(A)-5/0019/2015-16 & Del/Cit(A)- 5/0037/18-19 Arising Out Of The Appeals Before It Against The Orders Dated 21.03.2015 & 27.03.2018 Passed U/Ss 143(3) & 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Dcit, Circle-13(1), Delhi

For Appellant: Shri Satya Jeet Goel, AdvocateFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR

Section 271Section 271(1)(c)

also, the AO has not given a specific and conclusive finding as to if the cause of action for imposing penalty was concealment of income or furnishing of inaccurate particulars of income. As a matter of fact, on the basis of assessment order, it comes up that on the basis

Jsl Media Ltd., New Delhi vs. DCIT, New Delhi

Accordingly, the appeal in ITA No.9650/Del/2019 of the assessee is allowed

ITA 1004/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Aug 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year: 2012-13 Assessment Year : 2012-13 Jsl Media Limited, Vs Dcit, 28, Najafgarh Road, Circle-13(1), New Delhi – 110 015. New Delhi. Pan: Aaecp5027F (Appellant) (Respondent) Assessee By : Shri Satya Jeet Goel, Advocate Revenue By : Ms Harpreet Kaur Hansra, Sr. Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 28.08.2025 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Dated 15.12.2016 & 21.10.2019 Of The Commissioner Of Income-Tax (Appeals)-5, Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals No.Del/Cit(A)-5/0019/2015-16 & Del/Cit(A)- 5/0037/18-19 Arising Out Of The Appeals Before It Against The Orders Dated 21.03.2015 & 27.03.2018 Passed U/Ss 143(3) & 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Dcit, Circle-13(1), Delhi

For Appellant: Shri Satya Jeet Goel, AdvocateFor Respondent: Ms Harpreet Kaur Hansra, Sr. DR

Section 271Section 271(1)(c)

also, the AO has not given a specific and conclusive finding as to if the cause of action for imposing penalty was concealment of income or furnishing of inaccurate particulars of income. As a matter of fact, on the basis of assessment order, it comes up that on the basis

Ahmed Lakadia, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

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

ITA 498/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad27 Aug 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Varis Isani, AdovcateFor Respondent: Shri Abhijit, Sr. DR

Section 10(38)Section 115BSection 142(1)Section 147Section 271(1)(C)Section 68

initiating penalty proceedings u/s. 271(1)(C) and 271(1)(b) of the Income Tax Act without there being any element of concealment of income. 12. The Lrd. Assessing Authority has grievously erred in law while passing the order without providing proper and statutory time period to submit the documents

Manish Chawla, Delhi vs. Additional/ Joint/ Deputy/ Assistant Commissioner of Income-Tax/ Income-Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 2587/DEL/2025[2011-12]Status: DisposedITAT Delhi27 Aug 2025AY 2011-12

Bench: Shri M. Balaganeshmanish Chawla, Vs. Additional/ J-133, Saket, Joint/Deputy/Assistant New Delhi Commissioner Of Income-Tax/ Income Tax Officer, New Delhi Pan:Aiqpc2510H Assessee By : None Revenue By: Shri Manoj Kumar, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 27/08/2025

For Appellant: NoneFor Respondent: Shri Manoj Kumar, Sr. DR

Section 143(3)Section 147Section 271(1)(c)Section 44A

estimated income. It is trite law that no penalty could survive on estimated income as there cannot be any partial concealment and non-concealment of income. Hence, the levy of penalty u/s 271(1)(c) of the Act is hereby directed to be deleted. Accordingly, grounds raised by the assessee

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

In the result, all the captioned appeals and corresponding stay applications are dismissed

ITA 138/COCH/2025[2018-19]Status: DisposedITAT Cochin26 Aug 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 139(1)Section 147Section 148Section 270ASection 271(1)(c)

making additions on account of undisclosed income. Doing so the Assessing Officer also initiated penalty proceedings under section 271(1)(c) for concealment of income and levied penalties. For AY 2013-14, penalty of Rs.1,49,07,713/- was imposed. 3. Aggrieved by the order of the AO the assessee ... assessee and directed the AO to pass the order giving effect (OGE). The Ld. CIT(A) in penalty appeals observed that concealment of income was proved beyond doubt and upheld the penalties, with a direction to the AO to recompute the same in line with the OGE. 4. Dissatisfied with

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

In the result, all the captioned appeals and corresponding stay applications are dismissed

ITA 137/COCH/2025[2016-17]Status: DisposedITAT Cochin26 Aug 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 139(1)Section 147Section 148Section 270ASection 271(1)(c)

making additions on account of undisclosed income. Doing so the Assessing Officer also initiated penalty proceedings under section 271(1)(c) for concealment of income and levied penalties. For AY 2013-14, penalty of Rs.1,49,07,713/- was imposed. 3. Aggrieved by the order of the AO the assessee ... assessee and directed the AO to pass the order giving effect (OGE). The Ld. CIT(A) in penalty appeals observed that concealment of income was proved beyond doubt and upheld the penalties, with a direction to the AO to recompute the same in line with the OGE. 4. Dissatisfied with

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

In the result, all the captioned appeals and corresponding stay applications are dismissed

ITA 136/COCH/2025[2015-16]Status: DisposedITAT Cochin26 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 139(1)Section 147Section 148Section 270ASection 271(1)(c)

making additions on account of undisclosed income. Doing so the Assessing Officer also initiated penalty proceedings under section 271(1)(c) for concealment of income and levied penalties. For AY 2013-14, penalty of Rs.1,49,07,713/- was imposed. 3. Aggrieved by the order of the AO the assessee ... assessee and directed the AO to pass the order giving effect (OGE). The Ld. CIT(A) in penalty appeals observed that concealment of income was proved beyond doubt and upheld the penalties, with a direction to the AO to recompute the same in line with the OGE. 4. Dissatisfied with

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

In the result, all the captioned appeals and corresponding stay applications are dismissed

ITA 135/COCH/2025[2014-15]Status: DisposedITAT Cochin26 Aug 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 139(1)Section 147Section 148Section 270ASection 271(1)(c)

making additions on account of undisclosed income. Doing so the Assessing Officer also initiated penalty proceedings under section 271(1)(c) for concealment of income and levied penalties. For AY 2013-14, penalty of Rs.1,49,07,713/- was imposed. 3. Aggrieved by the order of the AO the assessee ... assessee and directed the AO to pass the order giving effect (OGE). The Ld. CIT(A) in penalty appeals observed that concealment of income was proved beyond doubt and upheld the penalties, with a direction to the AO to recompute the same in line with the OGE. 4. Dissatisfied with

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

In the result, all the captioned appeals and corresponding stay applications are dismissed

ITA 134/COCH/2025[2013-14]Status: DisposedITAT Cochin26 Aug 2025AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 139(1)Section 147Section 148Section 270ASection 271(1)(c)

making additions on account of undisclosed income. Doing so the Assessing Officer also initiated penalty proceedings under section 271(1)(c) for concealment of income and levied penalties. For AY 2013-14, penalty of Rs.1,49,07,713/- was imposed. 3. Aggrieved by the order of the AO the assessee ... assessee and directed the AO to pass the order giving effect (OGE). The Ld. CIT(A) in penalty appeals observed that concealment of income was proved beyond doubt and upheld the penalties, with a direction to the AO to recompute the same in line with the OGE. 4. Dissatisfied with

The Visnagar Nagrik Sahakari Bank Ltd., Mehsana vs. The ACIT, Circle-Gandhinagar (Previously DCIT, Patan Circle, Patan), Gandhinagar

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 738/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad26 Aug 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

For Appellant: Shri A P Nanavaty, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(4)

added the same to the total income of the assessee. He also directed initiation of penalty proceedings under section 271(1)(c) for concealment of income. 8. For A.Y. 2013-14 the assessee preferred appeal before CIT(A). The appeal before CIT(A) was delayed by more than 6 months

The Visnagar Nagrik Sahakari Bank Ltd (Under Liquidation), Mehsana vs. The ACIT, Circle-Gandhinagar (Previously DCIT, Patan Circle, Patan), Gandhinagar

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 1414/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad26 Aug 2025AY 2014-15

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

For Appellant: Shri A P Nanavaty, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(4)

added the same to the total income of the assessee. He also directed initiation of penalty proceedings under section 271(1)(c) for concealment of income. 8. For A.Y. 2013-14 the assessee preferred appeal before CIT(A). The appeal before CIT(A) was delayed by more than 6 months

Jhuma Chatterjee, Kolkata vs. I.T.O., Ward - 1(3), Asansol

In the result, the appeal of the assessee is allowed

ITA 2500/KOL/2024[2014-2015]Status: DisposedITAT Kolkata26 Aug 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Ito, Ward-1(3) Jhuma Chatterjee Aaykar Bhavan, Opposite Bf-151 Ground Floor, Sector-1, Ramakrishna School, Po Salt Lake, Kolkata-700064 Vs. Asansol, Pin-713305, West Bengal West Bengal (Appellant) (Respondent) Pan No. Ajepc3975K Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Sandip Sarkar, Dr Date Of Hearing: 17.07.2025 Date Of Pronouncement: 26.08.2025 O R D E R Per Rajesh Kumar, Am:

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Sandip Sarkar, DR

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

value of the property. Accordingly, the penalty proceedings under Section 271(1)(c) read with section 274 of the Act, were initiated for concealment of income by issuing notice dated 25.10.2016. 04. In the appellate proceeding, the learned CIT (A) reduced the addition to the extent ... thereafter recorded a finding that obviously the assessee has concealed the income and had not offered the tax, the correct income in ITR. Finally, the penalty of ₹60,835 was imposed equal to 100% of tax sought to be evaded by passing an order u/s271

Narayana Hrudayalaya Limited, Bengaluru vs. ACIT, Circle-2(3)(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 246/BANG/2025[2012-13]Status: DisposedITAT Bangalore26 Aug 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2012-13

For Appellant: Shri Monish Sowkar, AdvocateFor Respondent: Shri Thamba Mahendra, Jt.CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)Section 271Section 271(1)(c)Section 274Section 43B

Assessing Officer had correctly reached the conclusion that since the assessee had claimed excessive deductions knowing that they are incorrect; it amounted to concealment of income. It was tried Page 9 of 11 to be argued that the falsehood in accounts can take either of the two forms ... well as income in its Return, which details, in themselves, were not found to be inaccurate nor could be viewed as the concealment of income on its part. It was up to the authorities to accept its claim in the Return or not. Merely because the assessee had claimed

“concealment of income”

Leading authorities on concealment of income

Judgments citing concealment of income

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

Balreddy Gade, Secunderabad vs. Addl. CIT., Central Range-1, Hyderabad

Ranjit Pathak, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

Ranjit Pathak, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

Chromex, Mumbai vs. DCIT -17(1), Mumbai

Jsl Media Ltd, New Delhi vs. ACIT, Circle-13(2), New Delhi

Jsl Media Ltd., New Delhi vs. DCIT, New Delhi

Ahmed Lakadia, Ahmedabad vs. The ITO, Ward-5(3)(1), Ahmedabad

Manish Chawla, Delhi vs. Additional/ Joint/ Deputy/ Assistant Commissioner of Income-Tax/ Income-Tax Officer, Delhi

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

Koothery Narayanan Vijayan, Palakkad vs. ITO, Non Cop Ward 2(4) & Tps, Cochin

The Visnagar Nagrik Sahakari Bank Ltd., Mehsana vs. The ACIT, Circle-Gandhinagar (Previously DCIT, Patan Circle, Patan), Gandhinagar

The Visnagar Nagrik Sahakari Bank Ltd (Under Liquidation), Mehsana vs. The ACIT, Circle-Gandhinagar (Previously DCIT, Patan Circle, Patan), Gandhinagar

Jhuma Chatterjee, Kolkata vs. I.T.O., Ward - 1(3), Asansol

Narayana Hrudayalaya Limited, Bengaluru vs. ACIT, Circle-2(3)(1), Bangalore