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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

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 363/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 May 2025AY 2018-19

Bench: BEFORESHRI NARENDA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 362/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 May 2025AY 2017-18

Bench: BEFORESHRI NARENDA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 361/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 May 2025AY 2016-17

Bench: BEFORESHRI NARENDA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 360/MUM/2025[2015-16]Status: DisposedITAT Mumbai22 May 2025AY 2015-16

Bench: SHRI NARENDRA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 359/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 May 2025AY 2014-15

Bench: SHRI NARENDRA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 358/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 May 2025AY 2013-14

Bench: BEFORESHRI NARENDA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Shantilal Hirji Savla, Mumbai vs. DCIT CC 4(1), Mumbai

In the result, all the appeals of assessee bearing ITA Nos 357 to 363/Mum/2025 are allowed

ITA 357/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 May 2025AY 2012-13

Bench: BEFORESHRI NARENDA KUMAR BILLAIYA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Vinodkumar Bindal (virtually appeared) a/w Shri Satish KumarFor Respondent: Shri Dr Kishore Dhule - CIT DR
Section 143(3)Section 153ASection 153CSection 153DSection 250Section 56Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G”, MUMBAI BEFORESHRI NARENDA KUMAR BILLAIYA, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE

Vinod Kumar Soni, Ambikapur vs. Addl/JCIT(A)-1, Chandigarh

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

ITA 18/RPR/2025[2013-2014]Status: DisposedITAT Raipur21 May 2025AY 2013-2014

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.18/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Vinod Kumar Soni Moulviya Bandh, Namanakala, Chhattisgarh-497 001 Pan: Bukps0274H .......अपीलाथ" / Appellant बनाम / V/S. The Addl./Jt. Commissioner Of Income Tax(A)-1, Chandigarh. ……""यथ" / Respondent

For Appellant: Shri Abhay Kumar Tiwari &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 148Section 271(1)(b)Section 44ASection 69A

case, Ld. Assessing Officer determined the penalty proceedings U/s 271(1)(b), 271(1)(c) & 271F on account of furnishing inaccurate particulars and concealment of income. Ld. AO. Has initiated penalty without considering entire facts of the case. Hence, penalty initiated is bad in law, against law of natural justice

Krishnappa Gowder Kalyanasundaram, Coimbatore vs. DCIT, CC-3, Coimbatore

The appeal stand allowed accordingly

ITA 1905/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 May 2025AY 2014-15

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri N. Arjun Raj (Advocate) – Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -
Section 139Section 139(1)Section 153ASection 153A(1)Section 271(1)(c)Section 40A

Rs.13 Lacs as undisclosed business income and disallowance u/s 40A for Rs.1.80 Lacs. Consequently, penalty proceedings were initiated u/s 271(1)(c) for concealment of income. 2.2 In response to penalty show-cause notice, the assessee opposed levy of penalty on the ground that there was no concealment of income ... Lacs which was further added along with disallowance u/s 40A. Therefore, in terms of Explanation 5A to Sec.271(1)(c), the assessee had concealed its income to the extent of Rs.151.80 Lacs and accordingly, penalty of Rs.48.33 Lacs was levied. 2.3 The Ld. CIT(A) noted that the assessee offered

Krishnappa Gowder Kalyanasundaram, Coimbatore vs. DCIT, Central Circle-4, Coimbatore

The appeal stand allowed accordingly

ITA 1904/CHNY/2024[2013-14]Status: DisposedITAT Chennai21 May 2025AY 2013-14

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri N. Arjun Raj (Advocate) – Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -
Section 139Section 139(1)Section 153ASection 153A(1)Section 271(1)(c)Section 40A

Rs.13 Lacs as undisclosed business income and disallowance u/s 40A for Rs.1.80 Lacs. Consequently, penalty proceedings were initiated u/s 271(1)(c) for concealment of income. 2.2 In response to penalty show-cause notice, the assessee opposed levy of penalty on the ground that there was no concealment of income ... Lacs which was further added along with disallowance u/s 40A. Therefore, in terms of Explanation 5A to Sec.271(1)(c), the assessee had concealed its income to the extent of Rs.151.80 Lacs and accordingly, penalty of Rs.48.33 Lacs was levied. 2.3 The Ld. CIT(A) noted that the assessee offered

Usha Marazban Pithawalla, Mumbai vs. Assessing Officer, Navi Mumbai

In the result the appeal filed by the assessee stands dismissed as infructuous

ITA 2177/MUM/2025[2014-2015]Status: DisposedITAT Mumbai21 May 2025AY 2014-2015

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 144Section 144BSection 147Section 271Section 271(1)Section 271(1)(c)Section 274

demand of Rs. 81,98,633/- u/s 147 read with sec. 144 of the I.T. Act by stating "Penalty proceedings for concealment of income has been initiated separately by issue of notice u/s.274 r.w.s. 271(1)(c) of Income Tax Act, 1961. A show cause notice dated 23.03.2022 was issued

Kakoli Ganguly, Legal Heir of Haradhan Halder, Kolkata vs. ITO, Ward 12(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 314/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 May 2025AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.314/Kol/2025 Assessment Year: 2012-13 Kakoli Ganguly, Legal Heir Of Haradhan Halder.…………… ….……….Appellant 33, Banamanli Naskar Road, Kolkata – 700060. [Pan: Adypg8773F] Vs. Ito, Ward-12(1), Kolkata……………....................……........……...…..…..Respondent Appearances By: Shri Gaurav Mathur, Ca Appeared On Behalf Of The Assessee. Shri Archana Gupta, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 14, 2025 Date Of Pronouncing The Order : May 20, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 25.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, It Is Noted That There Is A Delay Of 14 Days In Filing The Instant Appeal Before The Tribunal. The Assessee Has Submitted An Application For Condonation Of Such Delay Explaining Reasons For The Delay. We, After Perusing The Petition Made In The Application, Satisfy That There Were Bona Fide & Sufficient Reasons For Such Delay. We, Therefore, Condone The Delay & Admit This Appeal For Adjudication.

Section 10(38)Section 142(1)Section 147Section 250Section 271(1)(c)

assessee at Rs.16,69,230/- and doing so, the Assessing Officer also initiated penalty u/s 271(1)(c) of the Act for concealment of income. 4. Aggrieved by the above order, the assessee preferred an appeal before the ld. CIT(A). However, the appeal of the assessee was dismissed I.T.A

Deputy Commissioner of Income Tax, Central Circle 1(1), Kolkata vs. Radheshyam Agarwala, Kolkata

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2607/KOL/2024[2020-21]Status: DisposedITAT Kolkata20 May 2025AY 2020-21

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

consequential search on the assessee’s son and the only fact that the penalty is to be levied is as the assessee concealed his income in comparison to the original return filed. It was the submission that the order of the ld. CIT(A) in the appeals under consideration ... would have been considered as return filed u/s.139(1) of the Act and consequently no penalty shall be leviable as there is no concealment of income nor furnishing of inaccurate particulars of income nor mis-reported or under-reported of any income. The revenue has not been able to dislodge

Deputy Commissioner of Income Tax, Central Circle 1(1), Kolkata vs. Radheshyam Agarwala, Kolkata

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2606/KOL/2024[2019-20]Status: DisposedITAT Kolkata20 May 2025AY 2019-20

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

consequential search on the assessee’s son and the only fact that the penalty is to be levied is as the assessee concealed his income in comparison to the original return filed. It was the submission that the order of the ld. CIT(A) in the appeals under consideration ... would have been considered as return filed u/s.139(1) of the Act and consequently no penalty shall be leviable as there is no concealment of income nor furnishing of inaccurate particulars of income nor mis-reported or under-reported of any income. The revenue has not been able to dislodge

Deputy Commissioner of Income Tax, Central Circle 1(1), Kolkata vs. Radheshyam Agarwala, Kolkata

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2605/KOL/2024[2018-19]Status: DisposedITAT Kolkata20 May 2025AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

consequential search on the assessee’s son and the only fact that the penalty is to be levied is as the assessee concealed his income in comparison to the original return filed. It was the submission that the order of the ld. CIT(A) in the appeals under consideration ... would have been considered as return filed u/s.139(1) of the Act and consequently no penalty shall be leviable as there is no concealment of income nor furnishing of inaccurate particulars of income nor mis-reported or under-reported of any income. The revenue has not been able to dislodge

Deputy Commissioner of Income Tax, Central Circle 1(1), Kolkata vs. Radheshyam Agarwala, Kolkata

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2604/KOL/2024[2017-18]Status: DisposedITAT Kolkata20 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

consequential search on the assessee’s son and the only fact that the penalty is to be levied is as the assessee concealed his income in comparison to the original return filed. It was the submission that the order of the ld. CIT(A) in the appeals under consideration ... would have been considered as return filed u/s.139(1) of the Act and consequently no penalty shall be leviable as there is no concealment of income nor furnishing of inaccurate particulars of income nor mis-reported or under-reported of any income. The revenue has not been able to dislodge

Deputy Commissioner of Income Tax, Central Circle 1(1) Kolkata, Kolkata vs. Radheshyam Agarwala, Kolkata

In the result, all the appeals of the revenue and cross objections of the assesse are dismissed

ITA 2603/KOL/2024[2016-17]Status: DisposedITAT Kolkata20 May 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri S.M.Surana, AdvocateFor Respondent: Shri Praveen Kishore, CIT-DR
Section 153ASection 153CSection 270ASection 271(1)(c)

consequential search on the assessee’s son and the only fact that the penalty is to be levied is as the assessee concealed his income in comparison to the original return filed. It was the submission that the order of the ld. CIT(A) in the appeals under consideration ... would have been considered as return filed u/s.139(1) of the Act and consequently no penalty shall be leviable as there is no concealment of income nor furnishing of inaccurate particulars of income nor mis-reported or under-reported of any income. The revenue has not been able to dislodge

Ramesh Kumar, Karnal vs. Income Tax Officer, Karnal

Appeal of the assessee is allowed

ITA 1279/DEL/2025[2012-13]Status: DisposedITAT Delhi20 May 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.1279/िद"ी/2025(िन.व. 2012-13) Ramesh Kumar, House No.2027, Opposite Civil Hospital, Nissing, Karnal, Haryana 132024 ...... अपीलाथ"/Appellant Pan: Azopk-6953-F बनाम Vs. Income Tax Officer, Aayakar Bhawan, 2Nd Floor, Sector 12, ..... "ितवादी/Respondent Karnal, Haryana 132001 अपीलाथ" "ारा/ Appellant By : Shri R R Singla, Chartered Accountant "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 20/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 20/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against An Ex-Parte Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 04.01.2025, For Assessment Year 2012-13. 2. Shri R R Singla, Appearing On Behalf Of The Assessee Submits That In Assessment Proceedings U/S. 144/147 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) Addition Was Made On Account Of Unexplained Cash Deposits Of Rs.28,50,000/- In Punjab National Bank, Karnal. The Assessee Failed To Respond To The Notices U/S. 148 Of The Act As Parallel Proceedings U/S. 148 R.W.S.

For Appellant: Shri R R Singla, Chartered AccountantFor Respondent: Shri Manoj Kumar, Sr. DR
Section 144Section 148Section 271(1)(c)Section 274Section 69A

Apex Court in the case of T. Ashok Pai vs CIT, 161 Taxman 340 3 has held that the expression ‘concealment of income’ and ‘furnishing inaccurate particulars’ carry different connotations. It has been repeatedly held by various High Courts that these two charges are independent and separate and the expressions

Som Nath Virmani and Sons HUF, Haryana vs. Income Tax Officer Ward-4(1), Gurgaon, Haryana

In the result, the appeal of the Assessee is allowed

ITA 5081/DEL/2024[2015-16]Status: DisposedITAT Delhi20 May 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri M. Balaganeshm/S. Som Nath Virmani & Vs. Income Tax Officer, Sons Huf, Ward-5(1), Flat No. 303, Soverign 1, Gurgaon Vatika City, Sector-49, Sohna Road, Gurgaon-122001 Haryana (Appellant) (Respondent) Pan: Aanhs1927F Assessee By : Dr. Rakesh Gupta, Adv Shri Somit Aggarwal, Adv Revenue By: Shri Manish Gupta, Sr. Dr Date Of Hearing 20/05/2025 Date Of Pronouncement 20/05/2025

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 144BSection 147Section 148Section 271(1)Section 271(1)(c)

determining total income at Rs 72,16,330/-. Penalty proceedings under section 271(1)(c ) of the Act were initiated for concealment of income vide notice dated 26-03-2022, which culminated in the levy of penalty in the sum of Rs 15,63,281/-. The Assessee pleaded that ... could not concentrate on the statutory compliances of filing of return in time. The Assessee pleaded that he had no intention to conceal any income nor evade any taxes. By the time he recovered from the trauma of the death of his son, the time limit for filing of return

Shashi Jivanlal Patel, Ahmedabad vs. The ITO, Ward-1(2)(2), Vadodara

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

ITA 1969/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad19 May 2025AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

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

facts in proposing the levying of penalty uls.274, without specifying the charge for which the penalty is proposed as to for concealment of income or for furnishing inaccurate particulars. Moreover, Ld. A.O. has not mentioned the charge in the assessment order, wherein it is simply mentioned that the penalty proceedings ... further submitted that the Assessing Officer had not mentioned, while initiating the penalty proceeding, as to whether the penalty was leviable for concealment of income or for furnishing of inaccurate particulars of income, either in the assessment order or in the penalty notice. 10. Per contra, Shri B.P. Srivastava