“concealment of income”

Maa Rupadevi Nagari Sahakari Path Sanstha Maryadi, Mumbai vs. ITO Ward 1(1), Mumbai

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

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2015-16 Maa Rupadevi Nagari Sahakari Income Tax Officer, Path Sanstha Maryadit, Ward-1(1), Pathebahadur Chawl, Vs. Thane. Tekdi Road No.33, Roopadevi, Wagle Estate, Thane (West), Maharashtra-400606. Pan : Aactm2530R (Appellant) (Respondent) For Assessee : Shri Satish Kadam For Revenue : Shri Annavaran Kosuri Date Of Hearing : 28-01-2026 Date Of Pronouncement : 03-02-2026 O R D E R Per Vikram Singh Yadav, A.M :

addition. He accordingly stated that it is a fit case to levy penalty u/s. 271(1)(c) of the Act for concealment of income and penalty of Rs. 18,56,379/- was levied @ 100% of tax sought to be evaded. 3 5. The assessee thereafter carried the matter in appeal ... associated with filed returns of income at the same time, they can also apply in cases of non- filing where the AO establishes concealment of income or furnishing of inaccurate particulars of income and accordingly penalty u/s. 271(1)(c) of the Act levied by the AO was held

Cool Diamond Private Limited, Mumbai vs. Income Tax Officer - 12(1)(1), Mumbai

In the result, the Assessee’s appeal is allowed, subject to verification as directed above

Bench: Shri Narender Kumar Choudhry & Shri Renu Jauhriassessment Year: 2013-14 Cool Diamond Private Ward Ito -12(1)(1), Limited, Room No. 129, Aayakar 2Nd Floor, Plot No. 97, Myco Bhawan, M K. Road, Vs. Industrial Area, Misc Industrial Mumbai – 400020. Area, Andheri East, Mumbai – 400093. Pan – Aadcc6707 (Appellant) (Respondent) Present For: Assessee By : Shri Vimal Punmiya, Ld. A.R. Revenue By : Shri Virabhadra S. Mahajan, Sr. D.R. Date Of Hearing : 02.12.2025 Date Of Pronouncement : 03.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 30.06.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In The Instant Case, An Information Was Received By The Ao From The Ddit (Inv.) Unit – 4 – Surat, With Regard To The Circular Transaction Of Rs.2,11,19,942/- By The Assessee With M/S. Seven Star Jewels Proprietary. On Perusing The Information, The Ao Observed That It Is Apparent That The Assessee Has Earned An Income To The Tune Of Rs.2,11,19,942/- But Has Not Included This 2 Cool Diamond Private Limited

amount of tax is calculated u/s 115BBE of the Act. Penalty proceeding u/s 271(1)(c) is being issued separately for concealment of income.” 9. The Assessee being aggrieved, challenged the aforesaid addition of Rs.2,11,19,942/- as well as the assessment order dated 29.03.2022 on various aspects including

P Cube Construction Private Limited, Mumbai vs. DCIT Cir.13(1)(2), Mumbai

In the result, the appeal filed by the assessee is

Bench: Shri Narender Kumar Choudhry

Officer had issued notice under section 274 read with section 271(1)(c) without being specific about the charge i.e. whether there was concealment of income or furnishing of inaccurate particulars by the assessee and that such notice was invalid and so was the order under section ... case of Trustar Diamond in ITA No.1542/ Mum/ 2025 are extracted as below for the sake of brevity: “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 in the case

Dy Commissioner of Income Tax (Int Tax.)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

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

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

Further, the AO also directed the initiation of penalty proceedings under section 271(1)(c) of the Act for concealment of income. 5. In the appeals before the Tribunal in quantum proceedings, the assessee raised the additional ground challenging the validity of the draft assessment ITA No.7520, 7521, 7522/Mum/2025 ... payable as per ITS 150, which was part of the order. The penalty under section 271(1)(c) is also initiated for the concealment of income in not ITA No.7520, 7521, 7522/Mum/2025 & CO No.394, 395, 396/Mum/2025 5 (A.Ys. 2007-08 to 2009-10) reporting the receipts. In view of this

Dy Commissioner of Income Tax (Int Tax.)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

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

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

Further, the AO also directed the initiation of penalty proceedings under section 271(1)(c) of the Act for concealment of income. 5. In the appeals before the Tribunal in quantum proceedings, the assessee raised the additional ground challenging the validity of the draft assessment ITA No.7520, 7521, 7522/Mum/2025 ... payable as per ITS 150, which was part of the order. The penalty under section 271(1)(c) is also initiated for the concealment of income in not ITA No.7520, 7521, 7522/Mum/2025 & CO No.394, 395, 396/Mum/2025 5 (A.Ys. 2007-08 to 2009-10) reporting the receipts. In view of this

Dy. Commissioner of Income Tax (Int Tax)- 3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

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

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year : 2007-08 Ita No.7522/Mum/2025 Assessment Year : 2008-09 Assessment Year : 2009-10 Deputy Commissioner Of Income Tax (International Taxation) – 3(2)(1), Room No.614, Kautilya Bhavan, Bkc, ……………. Appellant Mumbai – 400051 V/S Marriott International Inc. 303A, 304, Fulcrum, B Wing, Sahar P & T Colony So, Mumbai – 400099 Pan: Aaecm8040K ……………. Respondent

Further, the AO also directed the initiation of penalty proceedings under section 271(1)(c) of the Act for concealment of income. 5. In the appeals before the Tribunal in quantum proceedings, the assessee raised the additional ground challenging the validity of the draft assessment ITA No.7520, 7521, 7522/Mum/2025 ... payable as per ITS 150, which was part of the order. The penalty under section 271(1)(c) is also initiated for the concealment of income in not ITA No.7520, 7521, 7522/Mum/2025 & CO No.394, 395, 396/Mum/2025 5 (A.Ys. 2007-08 to 2009-10) reporting the receipts. In view of this

Dy. Commissioner of Income Tax (Int Tax.)-3(2)(1), Mumbai vs. Marriott International Inc, Mumbai

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

Further, the AO also directed the initiation of penalty proceedings under section 271(1)(c) of the Act for concealment of income. 5. In the appeal before the Tribunal in quantum proceedings, the assessee raised the additional ground challenging the validity of the draft assessment order passed ... payable as per ITS 150, which was part of the order. The penalty under section 271(1)(c) is also initiated for the concealment of income in not reporting the receipts. In view of this we do not find any reason to not to follow the decision of the honourable

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... mention of the default as, “for Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention of the default

Rajesh B. Jain As Legal Heir of Bhanwarlal M Jain, Mumbai vs. Income Tax Officer, Ward-19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... mention of the default as, “for Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention

Rajesh B. Jain As Legal Heir of Bhanwarlal M Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention of the default

Rajesh B, Jain As Legal of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am Ι.Τ.Α. No.1938/Mum/2024 (Assessment Year: 2008-09) Ι.Τ.Α. No.1937/Mum/2024 (Assessment Year: 2009-10) Ι.Τ.Α. No.1940/Mum/2024 (Assessment Year: 2010-11) Ι.Τ.Α. No.1939/Mum/2024 (Assessment Year: 2011-12) Ι.Τ.Α. No.1941/Mum/2024 (Assessment Year: 2012-13) Ι.Τ.Α. No.1942/Mum/2024 (Assessment Year: 2013-14) Ι.Τ.Α. No.1936/Mum/2024 (Assessment Year: 2014-15) Rajesh B. Jain As Legal Heir Of Bhanwarlal Jain, 171, 17Th Floor, Silver Arch, Petit Hall Compound, Nepeansea Road, Mumbai - 400006 Pan: Aafpj1924R Assessee -अपीलार्थी / Appellant Vs. Ito, Ward-19(1)(1), Piramal Chamber, Lalbaug, Mumbai-400012. Revenue - प्रत्यर्थी / Respondent : Assessee By : Shri Madhur Agarwal, Adv, Shri Fenil Bhat & Shri Sucheck Anchaliya, Ca

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... page 4) but with same analogy, having mention of the default as, "for furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee's reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... mention of the default as, “for Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

without appreciating the fact that the appellant had neither furnished any inaccurate particulars of income nor concealed any income during the relevant Assessment Year. 2. On the facts and circumstances of the case and in law, the Ld. CIT Appeal erred in confirming the penalty ... 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain furnishing of inaccurate particulars of income and / or concealment of income”. 11. Ld. AR further took us to assessee’s reply dated 26.05.2018, submitted before the Ld. AO, clarifying that such notice without specific mention of the default

Shree Krishna Woollen Mills Private Limited, Mumbai vs. DCIT, Mumbai

In the result, the appeal of the assessee is dismissed

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethshree Krishna Woollen Vs. Dcit Circle 15(3)(2), Aayakar Bhawan, Mills Pvt. Ltd. Mumbai-400020. Krishna Mills Compound, L. B.S. Marg, Bhandup West S.O, 400078, Mumbai. Pan/Gir No: Aabcs9353G (Appellant) (Respondent)

ITAT. Mumbai Bench. Therefore, the core issue is whether the assessee's conduct in claiming such receipt as exempt constitutes concealment of income" or "fumishing of inaccurate particulars warranting penalty under section 271(1)(c) of the Act. The assessee has argued that the claim was made under a bona