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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

Pankajkumar Chimanlal Lodhiya, Rakjot vs. The ACIT, Central Circle-2, Rajkot

ITA 81/RJT/2022[2014-15]Status: DisposedITAT Rajkot30 Apr 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 his income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated 10.07.2017, was issued and served ... account u/s 69A of the Income Tax Act, 1961. In respect of this addition, penalty u/s 271(1)(c) was also initiated “for concealment of income by furnishing inaccurate particulars of his income." 5 The assessing officer observed that the Hon'ble ITAT has restricted the addition on account

Pankajkumar Chimanlal Lodhiya, Rajkot vs. The ACIT, Central Circle-2, Rajkot

ITA 80/RJT/2022[2012-13]Status: DisposedITAT Rajkot30 Apr 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 ITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya H his income ... account u/s 69A of the Income Tax Act,1961. In respect of this addition, penalty u/s 271(1)(c) was also initiated "for concealment of income by furnishing inaccurate particulars of his income." 5 ITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya

Pankajkumar Chimanlal Lodhiya, Rajkot vs. The ACIT, Central Circle-2, Rajkot

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

ITA 79/RJT/2022[2011-12]Status: DisposedITAT Rajkot30 Apr 2025AY 2011-12

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of ITA No.76 to 81/RIT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya his income. Accordingly notice ... account u/s 69A of the Income Tax Act,1961. In respect of this addition, penalty u/s 271(I)(c) was also initiated “for concealment of income by furnishing inaccurate particulars of his income.” 5 ITA No.76 to 81/RIT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya

Pankajkumar Chimanlal Lodhiya, Rakjot vs. The ACIT, Central Circle-2, Rajkot

ITA 78/RJT/2022[2010-11]Status: DisposedITAT Rajkot30 Apr 2025AY 2010-11
Section 132Section 139(1)Section 143(3)Section 153ASection 154Section 271(1)(c)Section 271ASection 274Section 36(1)(iii)Section 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 ==End of OCR for page 3== ITA No.76 to 81/RJT/2022 ... account u/s 69A of the Income Tax Act,1961. In respect of this addition, penalty u/s 271(1)(c) was also initiated “for concealment of income by furnishing inaccurate particulars of his income.” 5 ==End of OCR for page 5== ITA No.76 to 81/RJT/2022

Pankajkumar Chimanlal Lodhiya, Rajkot vs. The Actit, Central Circle-2, Rajkot

ITA 77/RJT/2022[2009-10]Status: DisposedITAT Rajkot30 Apr 2025AY 2009-10

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 H ITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya his income ... account u/s 69A of the Income Tax Act,1961. In respect of this addition, penalty u/s 271(1)(c) was also initiated “for concealment of income by furnishing inaccurate particulars of his income.” 5 ==End of OCR for page 5== ITA No.76 to 81/RJT/2022

Pankaj Chimanlal Lodhiya, Rajkot vs. The ACIT, Central Circle-2, Rajkot

ITA 76/RJT/2022[2008-09]Status: DisposedITAT Rajkot30 Apr 2025AY 2008-09

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 his income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated 10.07.2017, was issued and served ... account u/s 69A of the Income Tax Act,1961. In respect of this addition, penalty u/s 271(1)(c) was also initiated "for concealment of income by furnishing inaccurate particulars of his income." 5 The assessing officer observed that the Hon'ble ITAT has restricted the addition on account

Saurabh Pravinbhai Patel and Brijesh Pravinbhai Patel AOP, Anand vs. Assessment Unit, Income Tax Department, New Delhi

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 1017/AHD/2023[2020-2021]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2020-2021

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 13ASection 143Section 80G

added back to the total income of the assessee and also initiated penalty proceedings u/s. 271(1)(c) of the Act for concealment of income." I.T.A No. 1017/Ahd/2023 A.Y. 2020-21 Page No 6 Saurabh Pravinbhai Patel And Brijesh Pravinbhai Patel AOP vs. Assessment Unit, ITD On further appeal

Assistant Commissioner of Income Tax, Central Circle - 4(1), Kolkata vs. Sendoz Commercials Private Limited, Kolkata

The appeal of the revenue is hereby dismissed

ITA 28/KOL/2025[2017]Status: DisposedITAT Kolkata30 Apr 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.28/Kol/2025 Assessment Year: 2017-18 Acit, Central Circle-4(1), Kolkata ………………………………….…..……Appellant Vs. Sendoz Commercials Pvt. Ltd…………..……...........……........……...…..…..Respondent 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] C.O. No.12/Kol/2025 (Arising Out Of I.T.A. No.28/Kol/2025) Assessment Year: 2017-18 Sendoz Commercials Pvt. Ltd …………..………….………………..….…..Cross-Objector 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] Vs. Acit, Central Circle-4(1), Kolkata.............................……........……...…..…..Respondent Appearances By: Shri A. K. Tulsyan, Fca & Deepak Mudhra, Aca, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2025 Date Of Pronouncing The Order : April 30, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal & The Assessee Has Filed The Corresponding Cross-Objection Against The Same Order Dated 27.08.2024 By The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Relating To Assessment Year 2017-18. 2. At The Outset, The Registry Has Informed That There Is A Delay Of 37 Days In Filing The Present Appeal. The Revenue Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case.

Section 115BSection 133(6)Section 143(2)Section 143(3)Section 148Section 69C

channels, Merely because the suppliers could not be traced at the given address would not automatically lead to a conclusion that there was concealment of income or furnishing of inaccurate particulars by the assessee. The assessee made a claim which was bona fide and the same was coupled with documentary

Virmabhai Ajabaji Patel, Mumbai vs. ITO 19(3)(5), Mumbai

In the result, the appeal is accordingly allowed in the above terms

ITA 544/MUM/2025[2009-2010]Status: DisposedITAT Mumbai30 Apr 2025AY 2009-2010

Bench: Om Prakash Kant & Shri Raj Kumar Chauhanvirmabhai Ajabbaji Patel Vs. Ito – 19(3)(5) Room No. 201, Matru 156, Room No. 6, Mistry Mandir Bldg, Tardeo Bldg, 2Nd Kumbharwala Road, Mumbai. (Vijesh Metal) – 400004. Pan/Gir No. Agkpp3389B (Applicant) (Respondent)

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 250bSection 271(1)(c)

hence he has to be held responsible for furnishing inaccurate particulars of income and as such penalty imposed is justified. 8. What is concealment of income or inaccurate particulars of such income as contemplated by Section 271(1)(c), has been explained by the Hon'ble Supreme Court ... estimation basis, it would fall within the mischief of Sec. 271(1)(c) of the Act making it a case of concealment of income or furnishing inaccurate particulars of income by the assessee. Moreover, the facts and circumstances of the present case are squarely covered by the judgment

Anatek Services Pvt Ltd, Mumbai vs. ITO Ward 14(1)(1), Mumbai

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

ITA 368/MUM/2025[2002-03]Status: DisposedITAT Mumbai30 Apr 2025AY 2002-03

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

Income Tax Act 1961 ignoring the fact that the Notice U/s 274 did not specify reason whether concealment of Income or furnishing of inaccurate particulars. Appellant prays that therefore the levy of penalty is bad at law and may please be deleted. GROUND II A. On the facts and circumstances ... notice issued u/s.274 of the Act, which is without striking of the irrelevant limb as to whether the same is for concealment of income or for furnishing of inaccurate particulars. As the additional ground raised by the assessee goes to the root of the case, we hereby admit the same

Anatek Services Pvt Ltd, Mumbai vs. Income Tax Officer 14(1)(1), Mumbai

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

ITA 367/MUM/2025[2001-02]Status: DisposedITAT Mumbai30 Apr 2025AY 2001-02

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

Income Tax Act 1961 ignoring the fact that the Notice U/s 274 did not specify reason whether concealment of Income or furnishing of inaccurate particulars. Appellant prays that therefore the levy of penalty is bad at law and may please be deleted. GROUND II A. On the facts and circumstances ... notice issued u/s.274 of the Act, which is without striking of the irrelevant limb as to whether the same is for concealment of income or for furnishing of inaccurate particulars. As the additional ground raised by the assessee goes to the root of the case, we hereby admit the same

Anatek Services Pvt Ltd, Mumbai vs. Income Tax Officer -14(1)(1), Mumbai

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

ITA 366/MUM/2025[1999-00]Status: DisposedITAT Mumbai30 Apr 2025AY 1999-00

Bench: Shri. Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Haridas BhatFor Respondent: Shri. Ram Krishn Kedia (SR. DR.)
Section 133Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

Income Tax Act 1961 ignoring the fact that the Notice U/s 274 did not specify reason whether concealment of Income or furnishing of inaccurate particulars. Appellant prays that therefore the levy of penalty is bad at law and may please be deleted. GROUND II A. On the facts and circumstances ... notice issued u/s. 274 of the Act, which is without striking of the irrelevant limb as to whether the same is for concealment of income or for furnishing of inaccurate particulars. As the additional ground raised by the assessee goes to the root of the case, we hereby admit

Shobha Ram Sharma, Mathura vs. National Faceless Appeal Centre, Delhi

In the result, appeal is allowed

ITA 111/AGR/2022[2012-13]Status: DisposedITAT Agra29 Apr 2025AY 2012-13

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2012-13

Section 144Section 250Section 271(1)(c)

receipt as above. The ld. AR contended that it is a case of an estimate against an estimate. As such, there was no concealment of income and accordingly no penalty is imposable as held in the case of ‘CIT vs. Raj Ban Singh

Jitendra Singh, Jamshedpur vs. Deputy/Assistant Commissioner of Income Tax, Circle-2, Jamshedpur

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 239/RAN/2023[2015-16]Status: DisposedITAT Ranchi29 Apr 2025AY 2015-16

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

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

account of unexplained creditors, ₹ 1,85,215/- as bogus expenses. Penalty proceedings were initiated under Section 271(1)(c) of the Act for concealment of income or furnishing inaccurate particulars of income. However, on appeal before the ld. CIT(A), the appellant could not make any compliance due to unavoidable

Rahul Coal India Private Limited, Surat vs. ITO TDS-2, Surat

In the result, appeal of the assessee is allowed

ITA 1220/SRT/2024[2013-14]Status: DisposedITAT Surat29 Apr 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1220/Srt/2024 Assessment Year: (2013-14) (Physical Hearing) Rahul Coal India Pvt. Ltd. Vs. The Addl. Cit (Tds), 429-432 Golden Point, Ring Road, Surat, Nr. Bsnl Office, Surat-395 002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcr1044D (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 18/02/2025 Date Of Pronouncement 29/04/2025

Section 133ASection 201(1)Section 206Section 206CSection 206C(1)Section 250Section 271CSection 271C(1)(a)

relevant provisions including section 271CA of the Act. The decisions referred to by the CIT(A) are on the issue of penalty for concealment of income u/s 271(1)(c) of the Act and not on the provisions of TCS or on 273B of the Act. On the other hand

Sandeep Kumar Yadav, Betul vs. National Faceless Assessment Centre, Delho

The appeal of the appellant is dismissed for statistical purpose

ITA 501/IND/2024[2013-14]Status: DisposedITAT Indore29 Apr 2025AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Paresh M Joshisandeep Kumar Yadav, Nfac, बना Palsyapalsya, Delhi म/ Palsya, Vs. The. Bhainsdehi, Betul (Pan: Afnpy3295D) (Appellant) (Revenue) Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.04.2025 Date Of Pronouncement 29.04.2025 आदेश/ O R D E R

Section 131Section 133(6)Section 139(4)Section 142(1)Section 143(3)Section 147Section 148Section 250Section 253Section 271(1)(b)

total income of the assessee. Tax is calculated as per provisions u/s 115BBE. Penalty u/s.271(1)(c) of the Income Tax Act for concealment of income” 11. The assessee has failed to file submission in response to notice u/s.142(1) of the Act on various date. Penalty proceedings, u/s.271

Bitthal Das Parwal, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

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

ITA 1348/JPR/2024[2011-12]Status: DisposedITAT Jaipur29 Apr 2025AY 2011-12

Bench: Him. 2. In This Appeal, The Assessee Has Raised The Following Grounds: -

For Appellant: Shri S.R. Sharma, C.A. &For Respondent: Shri Gautam Singh Choudhary, Addl.CIT
Section 132(1)Section 139Section 143(3)Section 153ASection 271(1)(c)

assessee for the year under consideration. Accordingly, the penalty proceedings u/s 271(1)(c) of the Income tax Act, 1961 were initiated on concealment of income from LTCG which was not disclosed in original return of income and penalty proceedings u/s 271(1)(c) were initiated for furnishing inaccurate particulars ... cause as to why the penalty u/s 271(1)(c) of the Income tax Act, 1961 should not be imposed for above referred concealment of income and furnishing inaccurate 5 Sh. Bittal Das Parwal vs. ACIT particulars of income. In response, the AR of assessee filed his written submission

Vasai Vikas Sahakari Bank Limited, Vasai, Thane vs. Income Tax Officer Circle-3, Thane, Qureshi Mansion, Gokhale Road

In the result, appeal of the assessee is accordingly allowed

ITA 1741/MUM/2025[2008-09]Status: DisposedITAT Mumbai29 Apr 2025AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2008-09 Vasai Vikas Sahakari Bank Limited Income Tax Officer Circle-3 Opp New English School, Vasai, Qureshi Mansion, Gokhale Mumbai-401201 Vs. Road, Mumbai- 400602 Pan No. Aaaav 0519 Q Appellant Respondent

For Appellant: Mr. Prateek JainFor Respondent: Smt. Kavita P. Kaushik, Sr. DR
Section 143(3)Section 263Section 271(1)(C)Section 271(1)(c)Section 43Section 43B

disallowing various expenses claimed as per the provisions of the Act and the Assessing Officer has rightly invoked the Impugned penal provisions for concealment of income. The contention of the appellant that penalty cannot be levied since it was mere rejection of claim cannot be accepted as there ... legal ground by way of oral plea that particular limb of charge for penalty, whether the penalty was initiated on account of concealment of income or furnishing of inaccurate particular of income , was not struck out in the notice issued for levy of penalty by the assessing officer

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5136/MUM/2024[2002-03]Status: DisposedITAT Mumbai29 Apr 2025AY 2002-03

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil
Section 143(3)Section 250Section 271(1)(c)

assessment of an assessee. Thereafter, in penalty proceedings, the competent authority has to probe into and decide whether there has been any concealment of income. But where there is a dispute as to whether such income allegedly concealed would be assessed in the hands of X or Y, unless

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5134/MUM/2024[2003-04]Status: DisposedITAT Mumbai29 Apr 2025AY 2003-04

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil
Section 143(3)Section 250Section 271(1)(c)

assessment of an assessee. Thereafter, in penalty proceedings, the competent authority has to probe into and decide whether there has been any concealment of income. But where there is a dispute as to whether such income allegedly concealed would be assessed in the hands of X or Y, unless