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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

Kesireddy Ravinder Reddy, Hyderabad vs. ITO Ward-11(1), Hyderabad

ITA 1617/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.1617 & 1722/Hyd/2025

For Appellant: Sri Mohd Afzal, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(1)Section 269SSection 271DSection 274Section 275

there is no satisfaction recorded by the AO stating that there is a violation of section 269SS, which caused escapement of income OR concealment of income. in the absence of such a satisfaction by the Assessing Officer in the case of assessee, the learned Commissioner erred in confirming the order

Sunil Kumar Ahuja, Hyderabad vs. ITO., Central Circle-1(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 128/HYD/2025[2009-10]Status: DisposedITAT Hyderabad11 Feb 2026AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.126, 127 & 128/Hyd/2025 ("नधा"रण वष"/Asst. Year:2007-08, 2008-09 & 2009-10) Sunil Kumar Ahuja, Vs. Income Tax Officer, Hyderabad. Central Circle-1(1), Pan: Ablpa2822L Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of Hearing: 02/02/2026 घोषणा क" तार"ख/Pronouncement: 11/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Three Appeals Are Filed By Shri Sunil Kumar Ahuja (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”), All Dated 25.11.2024 For The A.Y.2007-08, A.Y.2008-09 & A.Y.2009-10 Respectively. Since All These Three Appeals Are Related To The Same Assessee & The Issues Involved Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 271(1)(c)Section 274

suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion nor clearly specify whether the penalty was proposed for concealment of income or for furnishing of inaccurate particulars of income. It was submitted that both limbs under section 271(1)(c) of the Act carry different ... levied only when the assessee is made aware of the specific charge against it. The two limbs i.e. concealment of income and furnishing of inaccurate particulars of income, operate in different factual situations, and ambiguity in the notice strikes at the very root of the penalty proceedings. In this regard

Sunil Kumar Ahuja, Hyderabad vs. ITO., Central Circle-1(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 127/HYD/2025[2008-09]Status: DisposedITAT Hyderabad11 Feb 2026AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.126, 127 & 128/Hyd/2025 ("नधा"रण वष"/Asst. Year:2007-08, 2008-09 & 2009-10) Sunil Kumar Ahuja, Vs. Income Tax Officer, Hyderabad. Central Circle-1(1), Pan: Ablpa2822L Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of Hearing: 02/02/2026 घोषणा क" तार"ख/Pronouncement: 11/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Three Appeals Are Filed By Shri Sunil Kumar Ahuja (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”), All Dated 25.11.2024 For The A.Y.2007-08, A.Y.2008-09 & A.Y.2009-10 Respectively. Since All These Three Appeals Are Related To The Same Assessee & The Issues Involved Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 271(1)(c)Section 274

suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion nor clearly specify whether the penalty was proposed for concealment of income or for furnishing of inaccurate particulars of income. It was submitted that both limbs under section 271(1)(c) of the Act carry different ... levied only when the assessee is made aware of the specific charge against it. The two limbs i.e. concealment of income and furnishing of inaccurate particulars of income, operate in different factual situations, and ambiguity in the notice strikes at the very root of the penalty proceedings. In this regard

Sunil Kumar Ahuja, Hyderabad vs. ITO., Cetral Circle-1(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 126/HYD/2025[2007-08]Status: DisposedITAT Hyderabad11 Feb 2026AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.126, 127 & 128/Hyd/2025 ("नधा"रण वष"/Asst. Year:2007-08, 2008-09 & 2009-10) Sunil Kumar Ahuja, Vs. Income Tax Officer, Hyderabad. Central Circle-1(1), Pan: Ablpa2822L Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "वारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई क" तार"ख/Date Of Hearing: 02/02/2026 घोषणा क" तार"ख/Pronouncement: 11/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Three Appeals Are Filed By Shri Sunil Kumar Ahuja (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”), All Dated 25.11.2024 For The A.Y.2007-08, A.Y.2008-09 & A.Y.2009-10 Respectively. Since All These Three Appeals Are Related To The Same Assessee & The Issues Involved Are Identical, They Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Convenience & Brevity.

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 271(1)(c)Section 274

suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion nor clearly specify whether the penalty was proposed for concealment of income or for furnishing of inaccurate particulars of income. It was submitted that both limbs under section 271(1)(c) of the Act carry different ... levied only when the assessee is made aware of the specific charge against it. The two limbs i.e. concealment of income and furnishing of inaccurate particulars of income, operate in different factual situations, and ambiguity in the notice strikes at the very root of the penalty proceedings. In this regard

R J Corporation, Mumbai vs. Income Tax Officer, 42(1)(4), Mumbai

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

ITA 7715/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Feb 2026AY 2011-12

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

circumstances, under the garb of penalty proceedings, there ought not to be an occasion that such material again be labelled as amounting to concealment of income or furnishing of inaccurate particulars of income. If such approach is accepted, it would result in taking away the very basis of the assessment

R J Corporation, Mumbai vs. Income Tax Officer, 42(1)(4), Mumbai

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

ITA 7714/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Feb 2026AY 2010-11

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 250Section 271(1)(c)Section 274

circumstances, under the garb of penalty proceedings, there ought not to be an occasion that such material again be labelled as amounting to concealment of income or furnishing of inaccurate particulars of income. If such approach is accepted, it would result in taking away the very basis of the assessment

M/S. Cimmco Ltd., New Delhi vs. ITO, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5724/DEL/2016[2005-06]Status: DisposedITAT Delhi11 Feb 2026AY 2005-06

Bench: Shri Satbeer Singh Godara, Hon’Ble & Shri Naveen Chandra, Hon’Ble

Section 143(3)Section 250(6)Section 271(1)(c)Section 36

Department. We are of the view that theAO has failed to establish that there isa false claim and that there is any concealment of income or there is any inaccurate particulars furnished by the assessee. Following the decision of Hon’ble Supreme Court of India, in the case of Reliance

M/S. M M Brothers, Dhule vs. ITO, Ward 1, Dhule

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

ITA 477/PUN/2025[2014-15]Status: DisposedITAT Pune10 Feb 2026AY 2014-15

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Sharad A. VazeFor Respondent: Shri Bharat Andhale (Virtual)
Section 271(1)(c)Section 274

circumstances, under the garb of penalty proceedings, there ought not to be an occasion that such material again be labelled as amounting to concealment of income or furnishing of inaccurate particulars of income. If such approach is accepted, it would result in taking away the very basis of the assessment

Sagar Developers, Pune vs. ACIT Circle 3, Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2657/PUN/2025[2015-16]Status: DisposedITAT Pune10 Feb 2026AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2657/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Sagar Developers, Vs. Acit, Circle-3, Pune. S. No.27/22, Puneet Yash Arcade Dhanukar Colony, Kothrud, Pune- 411038. Pan : Aasfs3658Q Appellant Respondent Assessee By : Shri H. G. Sharma Revenue By : Shri M. M. Chate Date Of Hearing : 23.12.2025 Date Of Pronouncement : 10.02.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.09.2025 Passed U/S 271(1)(C) Of The It Act By Ld. Cit(A), Delhi-31 [‘Ld. Cit(A)’] For The Assessment Year 2015-16. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “On The Facts & In The Circumstances Of The Case & In Law- 1. The Ld. Cit (A) Erred In Confirming The Order Of Acit, Circle-3, Pune To The Extent Of Levy Of Penalty U/S 272(1)(C) Amounting To Rs. 3,45,81,680/- Being Income Offered During The Course Of Survey & Shown In Itr Filed Post The Survey Proceedings.

For Appellant: Shri H. G. SharmaFor Respondent: Shri M. M. Chate
Section 133ASection 143(3)Section 271(1)(c)Section 272(1)(c)

Authorities erred in law and on facts in levying a penalty u/s 272(1)(c) amounting to Rs. 3,45,81,680/- for concealment of income without appreciating the fact that the appellant has offered the regular income in Survey proceeding conducted on 25.08.2015 i.e. well before the due date ... returned income vide assessment order u/s 143(3) dated 13.12.2017 without making any addition to the returned income, as such the question of concealment of income does not arise. 3. The appellant craves leave to amend, alter, and modify any of the above Grounds of Appeal

Incometax Officer, Ward-1, Ballari vs. Bellary Urban Development Authority, Ballari

ITA 1523/BANG/2025[2015]Status: DisposedITAT Bangalore09 Feb 2026

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Ajith V, AdvocateFor Respondent: Shri Balusamy .N, JCIT-DR
Section 10(46)Section 139(1)Section 142(1)Section 143(2)Section 148Section 271(1)(c)

alternate ground that the income declared in the return filed pursuant to the notice issued u/s. 148 could not be treated as the concealment of income. The Ld.CIT(A) after considering the background of the case as well as the submissions made by the assessee and also relying ... show that the income declared by the assessee is in order. It is not the case of the revenue that the assessee had concealed the income which was found out by the department based on some other materials to impose penalty u/s. 271(1)(c) of the Act. As stated

Vijayawada Tollway Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is

ITA 1468/HYD/2025[2012-13]Status: DisposedITAT Hyderabad06 Feb 2026AY 2012-13
For Appellant: Shri A.V. Raghuram, Advocate
Section 143(3)Section 147Section 271(1)(c)

legal position noticed above, it is clear that the Assessing Officer has to form his own opinion and record his satisfaction of concealment of income or furnishing inaccurate particulars of income before initiating penalty proceedings under section 271(1)(c) of the Act. It is also clear that such satisfaction ... ratio laid down therein is not applicable to the instant case. 24. It is also relevant to note that whether the assessee has concealed his income or has deliberately furnished inaccurate particulars thereof is essentially a finding of fact which has to be spelt out by way of recording

Vijay Hiraman Jagdale, Pune vs. Income Tax Officer, Ward14(1 ), Pune

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

ITA 2932/PUN/2025[2010-11]Status: DisposedITAT Pune05 Feb 2026AY 2010-11

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2932/Pun/2025 निर्धारण वषा / Assessment Years: 2010-11 Vijay Hiraman Jagdale, V The Income Tax Officer, A1-106, Green County S. Ward-14(1), Pune. Phase-1,Pune Saswad Road, Near Hp Petrol Pump Fursungi, S.O.Pune – 412308. Pan: Akhpj4087D Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte Revenue By Smt Shraddha Nichal – Addl.Cit(Dr) Date Of Hearing 04/02/2026 Date Of Pronouncement 06/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2010-11 Dated 08.09.2025 Emanating From The Penalty Order Passed Under Section 271(1)(C) Of The Act, Dated 20.06.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 148Section 250Section 271(1)(c)

without specifying the correct limb, to an extent that penalty is initiated for furnishing of inaccurate particulars, and same is levied for concealment of Income, therefore entire proceedings are vitiated by incorrect charge and therefore penalty order needs to be quashed.” Findings & Analysis : 2. We have heard both the parties

Chiragkumar Rajendrabhai Shah, Mumbai vs. ITO Ward 30(1)(2), Mumbai

In the result, ITA No. 7130/M/2025 is allowed

ITA 7132/MUM/2025[2011-12]Status: DisposedITAT Mumbai05 Feb 2026AY 2011-12

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

itself, passed the penalty order under section 271(1)(c) of the Act, levying a penalty of Rs.70,00,000/- for concealment of income. 6. Though the Assessee challenged the validity of the penalty order by filing a first appeal before the Ld. Commissioner; however, could not get succeeded ... 7132/M/2025 4 Chiragkumar Rajendrabhai Shah ultimately levied the penalty of Rs.70,00,000/- under section 271(1)(c) of the Act for concealment of income. 10. Admittedly, in the notice dated 30.03.2014 issued under section 274 read with section 271(1)(c) of the Act, the Assessing Officer

Chiragkumar Rajendrabhai Shah, Mumbai vs. ITO Ward 30(1)(2), Mumbai

In the result, ITA No. 7130/M/2025 is allowed

ITA 7131/MUM/2025[2010-11]Status: DisposedITAT Mumbai05 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

itself, passed the penalty order under section 271(1)(c) of the Act, levying a penalty of Rs.70,00,000/- for concealment of income. 6. Though the Assessee challenged the validity of the penalty order by filing a first appeal before the Ld. Commissioner; however, could not get succeeded ... 7132/M/2025 4 Chiragkumar Rajendrabhai Shah ultimately levied the penalty of Rs.70,00,000/- under section 271(1)(c) of the Act for concealment of income. 10. Admittedly, in the notice dated 30.03.2014 issued under section 274 read with section 271(1)(c) of the Act, the Assessing Officer

Chiragkumar Rajendrabhai Shah, Mumbai vs. Income Tax Officer, Mumbai

In the result, ITA No. 7130/M/2025 is allowed

ITA 7130/MUM/2025[2009-10]Status: DisposedITAT Mumbai05 Feb 2026AY 2009-10

Bench: Shri Narender Kumar Choudhry & Shri Jagadish

For Appellant: Shri A K Sharma, AdvFor Respondent: Shri Virabhadra Mahajan, (SR. D.R.)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69C

itself, passed the penalty order under section 271(1)(c) of the Act, levying a penalty of Rs.70,00,000/- for concealment of income. 6. Though the Assessee challenged the validity of the penalty order by filing a first appeal before the Ld. Commissioner; however, could not get succeeded ... 7132/M/2025 4 Chiragkumar Rajendrabhai Shah ultimately levied the penalty of Rs.70,00,000/- under section 271(1)(c) of the Act for concealment of income. 10. Admittedly, in the notice dated 30.03.2014 issued under section 274 read with section 271(1)(c) of the Act, the Assessing Officer

Deputy Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dz Bank India Representative Office, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1161/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Feb 2026AY 2014-15

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

facts of the case and in law, the Id. CIT(A) has erred in deleting the penalty levied by the AO for concealment of income, when the penal proceedings were initiated consequent to reassessment proceedings u/s 147 of the Act. 2. Whether on the facts of the case

Deputy Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dz Bank India Representative Office, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1160/MUM/2025[2010-11]Status: DisposedITAT Mumbai04 Feb 2026AY 2010-11

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

facts of the case and in law, the Id. CIT(A) has erred in deleting the penalty levied by the AO for concealment of income, when the penal proceedings were initiated consequent to reassessment proceedings u/s 147 of the Act. 2. Whether on the facts of the case

Deputy Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dz Bank India Representative Office, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1159/MUM/2025[2009-10]Status: DisposedITAT Mumbai04 Feb 2026AY 2009-10

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

facts of the case and in law, the Id. CIT(A) has erred in deleting the penalty levied by the AO for concealment of income, when the penal proceedings were initiated consequent to reassessment proceedings u/s 147 of the Act. 2. Whether on the facts of the case

Deputy Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dz Bank India Representative Office, Mumbai

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1158/MUM/2025[2008-09]Status: DisposedITAT Mumbai04 Feb 2026AY 2008-09

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

facts of the case and in law, the Id. CIT(A) has erred in deleting the penalty levied by the AO for concealment of income, when the penal proceedings were initiated consequent to reassessment proceedings u/s 147 of the Act. 2. Whether on the facts of the case

Aromatrix Flora (P) Ltd., New Delhi vs. ACIT Circle 1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2100/DEL/2024[2011-12]Status: DisposedITAT Delhi04 Feb 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 80I

filing tax returns for past Page | 2 ITA No.2100/Del/2024 more than 20 years and had no mala fide intent or mens-rea to conceal any income as no additional tax would have been payable as the appellant had sufficient availability of MAT credit and thus a genuine, unintentional mistake ... statute could not be a basis to levy penalty u/s 271(1)(c) of the Act. 1.3. That the conclusion there was concealment of income by the learned Assessing Officer and, wrong particulars of income by the learned Commissioner of Income Tax (Appeals) itself vitiates the levy of penalty