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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

DCIT Cir - 3(1), Mumbai vs. M/S. Bajaj Auto Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 574/MUM/2007[2001-2002]Status: DisposedITAT Mumbai06 Sept 2024AY 2001-2002

Bench: Us, Revenue Has Raised The Following Grounds:-

Section 271(1)(c)Section 80

being disallowance of process know how expenses without appreciating the fact that unsubstantiated claim made by the assessee of these expenses amounts to concealment of income in view of explanation 1 to section 271(1)(c)". 3 "The appellant prays that the order of the CIT(A) on the above

Xplorer Consultancy Services Private Ltd., Gurgaon vs. DCIT Circle-27(2), Delhi

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

ITA 1374/DEL/2022[2014-15]Status: DisposedITAT Delhi06 Sept 2024AY 2014-15

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2014-15 Xplorer Consultancy Vs. Dcit Services Private Limited Circle – 27 (2) Plot No.3, First Floor, Delhi Sarhaul Sector-18, Gurgaon Pan No. Aaacx0611M (Appellant) (Respondent) Appellant By Ms. Rano Jain, Advocate Ms. Mansi Jain,Ca Respondent By Ms. Monika Dhami, Cit Dr Date Of Hearing: 01/08/2024 Date Of Pronouncement: 06/09/2024 Order Per Sudhir Kumar, Jm:

Section 143(3)Section 271(1)

audited books of account and considering that the records were destroyed in fire. The addition was not done on inaccurate particulars or concealment of income. 3. That any consequential relief to which the appellant may be entitled to under the foregoing grounds of appeal may kindly be granted

N R Constructions, Kakinada vs. Assistant Commissioner of Income Tax, Circle-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 18/VIZ/2024[2012-13]Status: DisposedITAT Visakhapatnam05 Sept 2024AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A. No. 18/Viz/2024 (धििाधरणिरध/ Assessment Year: 2012-13) N R Constructions V. Acit – Circle – 1 Kakinada 2-59-7, Shanthi Nagar Kakinada – 533003 Andhra Pradesh [Pan : Aabfn7969A] (अपीलार्/ Appellant) (प्र्/ Respondent) यरद्त्य्पयतय्यिध/ Assessee Represented By : Ms. Keerthana, Ar र्जसय्पयतय्यिध/ Department Represented By : Dr. Aparna Villuri, Sr.Ar सु्व्ईसम्पहो्ेय्यतयि/ Date Of Conclusion Of Hearing : 12.08.2024 घोषण्य्त्र्ख/Date Of Pronouncement : 05.09.2024 आदेश/O R D E R Per Shri S Balakrishnan: 1. This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Hereinafter In Short “Ld.Cit(A)”] Vide Din & Order No. Itba/Nfac/S/250/2023-

Section 143(1)Section 143(3)Section 271Section 271(1)(C)Section 271(1)(c)

have annulled the penalty proceedings u/s 271(1)(c) of the Act amounting to INR Rs.8,93,288, as the appellant has neither concealed any income nor furnished any inaccurate particulars of income. 2. The Ld. CIT(A) ought to have appreciated the fact that the notice issued under section ... without appreciating the fact that Explanation 1 could be invoked only if there is a concealment of income and not furnishing of inaccurate particulars. 4. The Ld. CIT(A) ought to have appreciated the fact that the penalty proceedings u/s 271(I)(c) of the Act is unsustainable in absence

Mahadevan Hariharan, New Delhi vs. ACIT, Circle -61(1), New Delhi

In the result, the penalty appeal; ITA No

ITA 1099/DEL/2023[2011-12]Status: DisposedITAT Delhi03 Sept 2024AY 2011-12

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 198Section 271(1)(c)

order on quantum addition, the AO levied penalty vide order dated 19.03.2019 passed under section 271(1)(c) of the Act for concealment of income and furnishing of inaccurate particulars of income of Rs.3,80,170/-. The appeal filed against the penalty order was also upheld ... which is not only disclosed in 26AS of the appellant/assessee buy also in the original ITR. The AO has levied penalty for concealment of income and furnishing of inaccurate particulars of income. It is not the case where the details furnished by 15 & 1099/Del/2023 the assessee were found

Mahadevan Hariharan, New Delhi vs. ACIT, Circle-61(1), New Delhi

In the result, the penalty appeal; ITA No

ITA 2636/DEL/2018[2011-12]Status: DisposedITAT Delhi03 Sept 2024AY 2011-12

Bench: Shri Kul Bharat & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 198Section 271(1)(c)

order on quantum addition, the AO levied penalty vide order dated 19.03.2019 passed under section 271(1)(c) of the Act for concealment of income and furnishing of inaccurate particulars of income of Rs.3,80,170/-. The appeal filed against the penalty order was also upheld ... which is not only disclosed in 26AS of the appellant/assessee buy also in the original ITR. The AO has levied penalty for concealment of income and furnishing of inaccurate particulars of income. It is not the case where the details furnished by 15 & 1099/Del/2023 the assessee were found

The Maharashtra State Co. Op. Hsg Finance Corp Ltd., Mumbai vs. ACIT-23(3), Mumbai

In the result, appeals of the assessee are partly allowed for statistical purposes

ITA 762/MUM/2024[2014-15]Status: DisposedITAT Mumbai02 Sept 2024AY 2014-15

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘B‘ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 143(3)

total income of the assessée under the head Income from House property. Penalty proceedings are hereby initiated us. 271(1)(c) for concealment of income. 6. Ld. CIT(A) too has confirmed the said addition holding that similar issue was involved in the A.Y.2012-13 and in that year

The Maharashtra State Co. Op. Hsg Finance Corp Ltd, Mumbai vs. ACIT-23(3), Mumbai

In the result, appeals of the assessee are partly allowed for statistical purposes

ITA 761/MUM/2024[2013-14]Status: DisposedITAT Mumbai02 Sept 2024AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 143(3)

total income of the assessée under the head Income from House property. Penalty proceedings are hereby initiated us. 271(1)(c) for concealment of income. 6. Ld. CIT(A) too has confirmed the said addition holding that similar issue was involved in the A.Y.2012-13 and in that year

Narayanan Sundaramahalingam Rajkumar, Chennai vs. The Assistant Commissioner of Income Tax, Chennai

In the result, the appeal of the assessee is allowed

ITA 763/CHNY/2024[2018-19]Status: DisposedITAT Chennai30 Aug 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R. Raghunathaआयकर अपील सं./Ita No.763/Chny/2024 िनधा:रण वष: /Assessment Year: 2018-19 Narayanan Sundaramahalingam The Asst. Commissioner Of Rajkumar, Vs. Income Tax, 27, Kanchi Natarajan Street, Central Circle-3(2), Vasudevan Nagar, Ashok Nagar, Chennai. Chennai – 600 083. [Pan: Adnpr 5990G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Assessee By : Shri N.R. Krishnamoorthy, Fca Ijथ" की ओर से /Revenue By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 02.08.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals)-20, Chennai [Hereinafter “Cit(A)] In Din & Order No.Itba/Apl/S/250/2023-24/1059981903(1), Dated 22.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2018-19 U/S.153C Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 21.09.2021. :- 2 -:

For Appellant: Shri N.R. Krishnamoorthy, FCAFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 132Section 143(3)Section 153CSection 270A

default has been committed to trigger the levy of penalty under the said section. Further, he stated that there has been no concealment of income and have not furnished any inaccurate particulars since the disallowance is based on the estimations made by the A.O. 6. Per contra

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1487/CHNY/2024[2016-17]Status: DisposedITAT Chennai30 Aug 2024AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1486/CHNY/2024[2015-16]Status: DisposedITAT Chennai30 Aug 2024AY 2015-16

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1485/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 Aug 2024AY 2014-15

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1484/CHNY/2024[2013-14]Status: DisposedITAT Chennai30 Aug 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1483/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 Aug 2024AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1482/CHNY/2024[2016-17]Status: DisposedITAT Chennai30 Aug 2024AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1481/CHNY/2024[2015-16]Status: DisposedITAT Chennai30 Aug 2024AY 2015-16

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1480/CHNY/2024[2014-15]Status: DisposedITAT Chennai30 Aug 2024AY 2014-15

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1479/CHNY/2024[2013-14]Status: DisposedITAT Chennai30 Aug 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Srinivasan Chandrasekara Chandilya, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, the appeal of the assesse is dismissed

ITA 1478/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 Aug 2024AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

For Appellant: Shri R.S.Balaji, AdvocateFor Respondent: Shri Dr.Samuel Pitta, JCIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 271A

miscalculated the additions in the OGE and that the specific charge was not mentioned as to whether assesse had concealed its income or had furnished inaccurate particulars thereof. 5.0 The only issue which arises in the matter is as to whether the penalty u/s 271(1)(c) has been lawfully ... accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024

Asst. Commissioner of Income Tax 8(2)(1), Mumbai vs. Piramal Enterprises Limited, Mumbai

ITA 3488/MUM/2024[2005-06]Status: DisposedITAT Mumbai30 Aug 2024AY 2005-06

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 115JSection 143(3)Section 271(1)(c)Section 274Section 35

assessee that the notice u/s 274 r.w.s. 271(1)(c) dated 27.12.2007 of the Act issued was defective as particular limb i.e. concealment of income or furnishing of inaccurate particulars of the income was not stricken off by the Assessing Officer while issuing notice for initiation of penalty, relying

M/S Shivalik Enterprises, Shimla vs. ITO, W-1, Shimla

ITA 1347/CHANDI/2019[2006-07]Status: DisposedITAT Chandigarh29 Aug 2024AY 2006-07

Bench: Shri Sanjay Garg& Dr. B.R.R. Kumar

For Appellant: NoneFor Respondent: Sh. Ashish Abrol, CIT DR
Section 271Section 801CSection 80I

however, deleted the penalty observing that it was not a case of furnishing of inaccurate particulars of income on concealment of income which is the pre- condition for levy of penalty u/s 271(l)(c) of the Act. The Revenue is, thus, in appeal before us agitating the above action ... expansion of the unit. Even otherwise, we do not find that this is a case of furnishing of inaccurate particulars of income or concealment of income. The assessee under the bonafide belief claimed the deduction u/s 80IC of the Act. 6. In view of this, we do not find