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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

Anitha Texcot (India) Private Limited, Tiruppur vs. PCIT - 2, Chennai

In the result, appeals filed by the assessee for all the assessment years are allowed

ITA 1138/CHNY/2024[2019-20]Status: DisposedITAT Chennai25 Sept 2024AY 2019-20

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1137 To 1139/Chny/2024 िनधा"रण वष"/Assessment Years: 2018-19 To 2020-21 V. M/S. Anitha Texcot (India) Pvt. Ltd., The Dcit, 10/14, Bridge Way Colony Extension, Central Circle-1, Lakshmi Nagar, Coimbatore. Tiruppur-641 607. [Pan:Aajca 4205 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.Suraj Nahar, CAFor Respondent: Mr.R. Clement Ramesh –
Section 132Section 153ASection 263Section 270A

that "on examination of the records, it is found that the Assessing Officer had in the assessment order established that the Assessee had concealed his income by filing inaccurate particulars". There is no such finding in the order of assessment. The Principal Commissioner seems to have distorted the order ... Commissioner is to that extent perverse. 15. In our view, in the absence of any finding of the Assessing Officer with regard to concealment of income or with regard to furnishing of inaccurate particulars of income, the Commissioner clearly erred in holding that omission to record satisfaction to initiate penalty

Anitha Texcot (India) Private Limited, Tiruppur vs. PCIT - 2, Chennai

In the result, appeals filed by the assessee for all the assessment years are allowed

ITA 1137/CHNY/2024[2018-19]Status: DisposedITAT Chennai25 Sept 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1137 To 1139/Chny/2024 िनधा"रण वष"/Assessment Years: 2018-19 To 2020-21 V. M/S. Anitha Texcot (India) Pvt. Ltd., The Dcit, 10/14, Bridge Way Colony Extension, Central Circle-1, Lakshmi Nagar, Coimbatore. Tiruppur-641 607. [Pan:Aajca 4205 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.Suraj Nahar, CAFor Respondent: Mr.R. Clement Ramesh –
Section 132Section 153ASection 263Section 270A

that "on examination of the records, it is found that the Assessing Officer had in the assessment order established that the Assessee had concealed his income by filing inaccurate particulars". There is no such finding in the order of assessment. The Principal Commissioner seems to have distorted the order ... Commissioner is to that extent perverse. 15. In our view, in the absence of any finding of the Assessing Officer with regard to concealment of income or with regard to furnishing of inaccurate particulars of income, the Commissioner clearly erred in holding that omission to record satisfaction to initiate penalty

Kay Kay Synthetics, Mumbai vs. I.T.O. National Faceless Assessment Centre, Delhi, Not Known

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

ITA 3959/MUM/2024[ASSESSMENT YEAR 2011-12]Status: DisposedITAT Mumbai25 Sept 2024

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalkay Kay Synthetics, Vs. I.T.O, Nfac, 201-202, Anna New Delhi. Apartments, 2Nd Floor, 14 Main Avenue, Santacruz (W), Mumbai-400054. Pan/Gir No. : Aaafk0934D Appellant .. Respondent Appellant By : Shri Vimal Punmiya.Ar Respondent By : Shri B.B. Nagawe, Sr. Dr Date Of Hearing 23.09.2024 Date Of Pronouncement 25.09.2024 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of National Faceless Appeal Centre(Nfac) Delhi / Cit(A), Passed U/Sec 271(1)(C) & U/Sec 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Vimal Punmiya.ARFor Respondent: Shri B.B. Nagawe, Sr. DR
Section 143(3)Section 271(1)(c)Section 274Section 275

vide notice issued u/s. 274 r.w.s. 271 of the Act dated 14-03- 2016 has initiated penalty proceedings u/s. 271(1)(c) for concealment of income as well as for furnishing inaccurate particulars of income, thus the penalty order passed is bad in law. 3. The Learned C.I.T. (Appeals), NFAC

Nitin Prabhakar Vaidya, Nagpur vs. ITO Ward 1(5), Nagpur

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

ITA 67/NAG/2024[2013-2014]Status: DisposedITAT Nagpur24 Sept 2024AY 2013-2014

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe

circumstances of the case and in law, the CIT(A) NFAC has erred in law by upholding the penalty when there was no concealment of income nor any inaccurate particulars were submitted by the assessee.” 2 Nitin Prabhakar Vaidya ITA no.67/Nag./2024 When this appeal is taken up for hearing

Sankarlingam Sankar Through His Legal Heir Ganesh Shankar, Mumbai vs. ACIT Circle 17(1), Mumbai

ITA 707/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Sept 2024AY 2012-13

Bench: Smt. Kavitha Rajgopal & Shri Gagan Goyal

For Appellant: Shri Gajendra Golcha, Ld. ARFor Respondent: Ms. Rajeshwari Menon, Ld. DR
Section 139Section 143(3)Section 148Section 250Section 271(1)Section 271(1)(c)

issued on a dead person and hence the penalty u/s. 271(1)(c) of the Act of Rs. 22,25,518/- for concealment of income may be deleted. 3) The NFAC failed to appreciate that Assessment Order u/s. 143(3) r.w.s ... passed against a dead person and hence the penalty u/s. 271(1)(c) of the Act of Rs. 22,25,518/- for concealment of income may be deleted. 4) The NFAC failed to appreciate that the Learned Assessing Officer has erred in levying penalty

ITO-22(1)(1), Mumbai, Piramal Chamber vs. Gehrilal Rooplal Paliwal, Andheri East

In the result, the appeal of the Revenue is partly allowed

ITA 3614/MUM/2024[2011-12]Status: DisposedITAT Mumbai24 Sept 2024AY 2011-12

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri V.K. Chaturvedi, Sr. DR
Section 148Section 68

assessee. Penalty proceedings u/s 271(1)(c) of the I.T Act. 1961 are initiated for furnishing inaccurate particulars of income and concealment of income. 4. The AO also noticed that the assessee has deposited a sum of Rs. 30,98,500/- and called on the assessee to furnish the source

Sri. Sumeru Housing Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bangalore

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

ITA 1471/BANG/2024[2015-16]Status: HeardITAT Bangalore23 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri Nagarajan, Director of the CompanyFor Respondent: Sri V. Parithivel, D.R
Section 144Section 250Section 271Section 271(1)(c)Section 274

learned authorities below have failed to appreciate that the mere disallowance of expenses or claims by the AO does not amount to concealment of income or furnishing inaccurate particulars. A genuine difference of opinion on the allowability of certain expenses should not be equated with concealment, more particularly when

Nilima Kothari, Indore vs. The Income Tax Officer, National Faceless Asstt. Centre, Indore

In the result appeal of the assessee is allowed as per terms indicated above

ITA 259/IND/2024[2016-17]Status: DisposedITAT Indore20 Sept 2024AY 2016-17

Bench: Shri Manish Boradsmt. Neelima Kothari, Income Tax Officer, 601, N.R.K. Villas, Delhi Vs. 22/2 Manoramaganj, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Adnpk7832J Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 08.08.2024 Date Of Pronouncement 20.09.2024

Section 10(38)Section 147Section 148Section 151Section 68

apply. In comparison, the extended period of ten years would apply in serious tax evasion cases where there was evidence of concealment of income of Rs.50.00 lacs or more in the given period. It was further held that Paragraph 6.1 and 6.2 (ii) of the instruction dated 11.05.2022 issued ... assessment to 3 years from the present 6 years. In serious tax evasion cases too, only where there is evidence of concealment of income of ₹50 lakh or more in a year, can the assessment be re-opened up to 10 years. Even this reopening can be done only after

Vijay M. Mistry Construction P. Ltd., Ahmedabad vs. NFAC (Delhi) AO Jurisdiction the DCIT, Circle-4(1)(1), Ahmedabad

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

ITA 1105/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad19 Sept 2024AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 271(1)(c)Section 44ASection 80I

assessee was not carrying out the projects as a developer, but only as a works Contractor. Therefore Ld. A.O. initiated penalty proceedings for concealment of income on the claim of deduction u/s 80IA(4) of the Act. 3. During the penalty proceedings, the assessee submitted that there is no concealment ... fact that the claim of deduction u/s 80IA(4) which was originally denied to the assessee has resulted in invoking penalty proceedings for concealment of income. Now the Co-ordinate Bench has held that the assessee is eligible to claim deduction u/s 80IA(4) as a developer. Thus the penalty

Saroj Gupta, Ujjain vs. ITO NFAC, Local Jurisdictional Office Ujjain

ITA 61/IND/2024[2014-15]Status: DisposedITAT Indore19 Sept 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisaroj Gupta, W/O Chandrabhan Gupta, 14, Chandra Bhawan, Fawwara Chowk, Ujjain (Appellant/Assessee) Ito, (Respondent/Revenue) Pan: Acapg0409K Assessee By Shri Sharad Jain, Ca & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.09.2024 Date Of Pronouncement 19.09.2024 आदेश/Order Per B.M. Biyani, A.M.: Feeling Aggrieved By Appeal-Order Dated 30.11.2023 Passed By Learned Commissioner Of Income-Tax (Appeals)-Nfac, Delhi [“Cit(A)”], Which In Turn Arises Out Of Penalty-Order Dated 05.01.2022 Passed By Learned Nfac, Delhi [“Ao”] U/S 271(1)(C) Of The Income-Tax Act, 1961 [“The Act”] For Assessment- Year [“Ay”] 2014-15, The Assessee Has Filed This Appeal.

Section 142(1)Section 147Section 148Section 271(1)(c)Section 274

that the assessee had not filed (original) return for AY 2014-15. The AO also initiated penalty proceeding u/s 271(1)(c) for concealment of income. Simultaneously, the AO also issued notice dated 22.12.2019 u/s 274 r.w.s. 271(1)(c) followed by another notice dated 17.08.2021. Ultimately, the AO imposed

ACIT, Amravati Circle, Amravati vs. Chandrapur Dist Central Co-Op Bank Ltd, Chandrapur

In the result, appeal filed by the Revenue is dismissed

ITA 398/NAG/2023[2014-15]Status: DisposedITAT Nagpur18 Sept 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandeep Salonkhe
Section 271(1)(c)Section 36Section 36(1)Section 36(1)(viia)

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 assessee had claimed the expenditure

Dr. B.G. Memorial Trust, Kolkata vs. ITO, Ward-1(2), Exemption, Kolkata

The appeal of the assessee is treated as allowed for statistical purposes

ITA 680/KOL/2024[2013-14]Status: DisposedITAT Kolkata13 Sept 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.680/Kol/2024 Assessment Year: 2013-14 Dr. B. G. Memorial Trust..…….…....…………….......…....………....Appellant 6/1, Sarat Chatterjee Avenue Rabindra Sarovar, Kolkata – 700029. [Pan: Aaatd5235A] Vs. Ito, Ward-1(2), Exempt, Kolkata...........................................…..…..... Respondent Appearances By: Shri S. M. Surana, Ar & Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 27, 2024 Date Of Pronouncing The Order : September 13, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 18.03.2024 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. The Brief Facts Of The Case Are That The Assessee Was Registered As A Charitable Institution U/S 12 Of The Act. The Assessee Claimed Deduction Of Income Being A Charitable Institution U/S 11 Of The Act. During The Assessment Proceedings, The Assessing Officer Noted That The Cit(Exemption) Vide Order Dated 22.02.2016 U/S 12Aa(3) Of The Act Has Withdrawn & Cancelled Registration Granted Earlier To The Assessee-Trust. In View Of The Said Cancellation Of Registration, The

Section 11Section 12Section 12ASection 250Section 40Section 40A

Assessing Officer, however, ignored the aforesaid explanation given by the assessee and observed that the assessee had increased assets by way of concealment of income and inflated expenses etc. and added the difference of Rs.59,58,659/- in respect of closing balance of the corpus fund arrived at after comparing

Ashok Goyai, Himachal Pradesh vs. DCIT, Central Circle-2, Noida

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 2779/DEL/2024[2013-14]Status: DisposedITAT Delhi12 Sept 2024AY 2013-14

Bench: Shri Vikas Awasthyआअसं.2779/िद"ी/2024 (िन.व. 2013-14) Ashok Goyal H.No. 228/48, Ward No. 11, Devi Nagar (115), Tehsil Paonta Sahib, Sirmaur, Himachal Pradesh 173025 ...... अपीलाथ"/Appellant Pan: Abepg-4250-F

For Appellant: Ms. Tanya, AdvocateFor Respondent: Ms. Shivani Bansal, Sr. DR
Section 132Section 147Section 148Section 153ASection 271(1)(c)

fresh addition was made. However, the AO initiated penalty proceedings u/s. 271(1)(c) of the Act for concealment of income in respect of unexplained expenditure amounting to Rs. 7,11,373/-. The ld. Counsel for the assessee submits that once return of income is accepted and no addition ... operation, the assessee would not have offered unexplained expenditure to tax and the said income would have escaped tax net. The assessee had concealed the income, therefore penalty proceedings u/s. 271(1)(c) of the Act have been rightly initiated and accordingly penalty has been levied. 3. Both sides heard

Dwarka Gems Limited, Jaipur vs. Asst. Commissioner of Income Tax, Jaipur

ITA 847/JPR/2024[2010-2011]Status: DisposedITAT Jaipur11 Sept 2024AY 2010-2011
For Appellant: Shri Harshit Agarwal, CAFor Respondent: Smt. Monisha Choudhary, Addl. CIT-DR
Section 143(3)Section 271(1)Section 271(1)(c)Section 274Section 40Section 80I

erred in confirming the action of the AO in levying penalty u/s 271(1)(c) of the Act on charge of concealment of income when all the facts were duly disclosed in return of income, thus penalty imposed for concealment of income is not in accordance with law and deserves ... initiating penalty proceeding u/s 271(1)(c) and further challenged the action of ld. CIT(A) in confirming the penalty on charge of concealment of income by ignoring the fact that all the details are duly disclosed by the assessee company in the return of income and therefore, the same

B M Manjunatha Gupta, Shivamogga vs. Income Tax Officer, Ward-3, Shivamogga

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

ITA 1276/BANG/2024[2012-13]Status: HeardITAT Bangalore11 Sept 2024AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2012-13

For Appellant: Sri Joseph Varghese, A.RFor Respondent: Sri V. Parithivel, D.R
Section 133ASection 250Section 271Section 274

various irregularities, since the Notice of penalty is not clear under which limb of penalty the penalty proceeding shave been initiated whether for concealment of income Or furnishing of inaccurate particulars of income and consequently the learned Commissioner of Income tax [Appeals] ought to have cancelled the order of penalty ... 730/on an addition made of Rs. in the order of assessment, requires to be deleted since there is no concealment of income nor furnishing of inaccurate particulars of income, on the facts and circumstances of the case. 7. The learned Commissioner of Income-tax [Appeals] failed to appreciate the fact

ACIT Circle 54(1), New Delhi vs. Swadesh Kumar Mishra, Gurgaon

In the result, appeal filed by the assessee i

ITA 6043/DEL/2019[2009-10]Status: DisposedITAT Delhi11 Sept 2024AY 2009-10

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144(1)Section 145(3)Section 24Section 40Section 40A(3)

Penalty u/s 40(a)(ia)) 27. With regard to assessee’s appeal, Ld AR submitted that there is no concealment of income as there is no merit in disallowance made by AO and confirmed by CIT(A). Disallowances are not warranted as each payment was less than the amount prescribed ... Further submitted that mere disallowance of a claim made in the Return would not amount to giving inaccurate particulars of income or concealment of income. [Commissioner of Income Tax v. Reliance Petroproducts Pvt. Ltd. (2010) 322 ITR 158]. 27.2 Technical disallowances like disallowance of freight expenses or auditor's fees

M/S Himachal Fashion Pvt. Ltd., Ludhiana vs. ITO, W-6(3), Ludhiana

In the result, the appeal of the Assessee is allowed

ITA 8/CHANDI/2020[2012-13]Status: DisposedITAT Chandigarh10 Sept 2024AY 2012-13

Bench: Shri Krinwant Sahay & Shri Paresh M. Joshiआयकर अपील सं./ Ita No. 8/Chd/2020 िनधा"रण वष" / Assessment Year: 2012-13

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Shri Danish Abdullah, JCIT, Sr. DR
Section 139(1)Section 271Section 271(1)(c)Section 27lSection 80Section 80ASection 80I

that the assessee made a computational error in its return — Contents of the tax audit report suggest that there was no question of concealment of income or furnishing of inaccurate particulars by the assessee —All that has happened is that the assessee failed to add back the provision for gratuity

Dipakbhai Jagdishbhai Patel, Vadodara, Gujarat vs. Income Tax Officer, Ward 3(1)(3), Vadodara (Now Income Tax Officer, Ward 3(1)(4), Vadodara), Gujarat

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

ITA 1079/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

For Appellant: Respondent by: Shri Sudhakar Verma, Sr. DRFor Respondent: Shri Sudhakar Verma, Sr. DR
Section 147Section 148Section 69A

extent of Rs. 97,66,506/- and hence, penalty proceedings u/s 271(1)(c) of the Act are also initiated for concealment of income. 5. As the assessee has not offered interest income of Rs. 3099/- by filing return of income, therefore 4. In appeal, the Ld.CIT(A) dismissed

Senbo Engineering Limited, Kolkata vs. DCIT, Cir-11, Kolkata.

ITA 1377/KOL/2023[2007-08]Status: DisposedITAT Kolkata09 Sept 2024AY 2007-08

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Years: 2007-08 Senbo Engineering Limited, Deputy Commissioner Of 87, Lenin Sarani, Vs Income Tax, Circle-11, Kolkata - 700013 Kolkata - 700013 (Pan: Aadcs6138B) (Appellant) (Respondent)

For Appellant: Shri S. Bhattacharya, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 143(3)Section 250Section 80Section 80I

claim of deduction u/s 80IA is rejected. This denial also AY: 2007-08 attracts initiation of penalty provisions u/s 271(1)(c) for concealment of income and filing inaccurate particulars of income. 7. Before the Ld. CIT(A), the assessee submitted as under in the Statement of Facts filed with

Vishnu Kumar, Bharatpur vs. ACIT Or JCIT Or DCIT Or Asst. CIT Or ITO, National Faceless Assessment Centre, Bharatpur

ITA 85/JPR/2024[2015-16]Status: DisposedITAT Jaipur06 Sept 2024AY 2015-16

Bench: This Appellate Tribunal, Feeling Aggrieved By The Order Dated 08.12.2023 Passed, U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “ The Act”), By Learned Cit(A), Nfac, Delhi, Whereby His Appeal Relating To Assessment Year 2015-16 Has Been Dismissed. 2. The Assessee Was Before Learned Cit(A), Having Felt Dissatisfied With The Assessment Order Dated 29.03.2022 Passed By The Assessing

For Appellant: Shri Mukesh Soni, AdvFor Respondent: Shri Arvind Kumar, (CIT)
Section 133(6)Section 148Section 151Section 250Section 68

satisfied that the assessee has concealed the particulars of income. Accordingly, penalty u/s. 271(1)(c) of the Act is separately initiated for concealment of income. For clarity section 68 reads as under :- X x x x x x x x” 20 Sh. Vishnu Kumar 32. Significant to note that