← All Phrases

“furnishing inaccurate particulars”

PenaltySection 271(1)(c)Section 271(1)(c)2,073 judgments

The decision most relied on for furnishing inaccurate particulars is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on furnishing inaccurate particulars

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 furnishing inaccurate particulars

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 890/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

wherein it was held that making a claim which is not accepted in law does not ipso facto amount to furnishing inaccurate particulars of income. It was urged that since the matter was one of interpretation and estimation, no penalty was exigible. 9. The learned CIT(A), after carefully evaluating ... every disallowance or addition. It can be imposed only when there is clear evidence that the assessee has either concealed income or furnished inaccurate particulars. In the present case, there is neither concealment nor inaccuracy. What has happened is nothing more than an inadvertent duplication of a claim, all facts

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

ITA 889/MUM/2025[2013-14]Status: DisposedITAT Mumbai29 Sept 2025AY 2013-14
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

wherein it was held that making a claim which is not accepted in law does not ipso facto amount to furnishing inaccurate particulars of income. It was urged that since the matter was one of interpretation and estimation, no penalty was exigible. 9. The learned CIT(A), after carefully evaluating ... every disallowance or addition. It can be imposed only when there is clear evidence that the assessee has either concealed income or furnished inaccurate particulars. In the present case, there is neither concealment nor inaccuracy. What has happened is nothing more than an inadvertent duplication of a claim, all facts

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 888/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

wherein it was held that making a claim which is not accepted in law does not ipso facto amount to furnishing inaccurate particulars of income. It was urged that since the matter was one of interpretation and estimation, no penalty was exigible. 9. The learned CIT(A), after carefully evaluating ... every disallowance or addition. It can be imposed only when there is clear evidence that the assessee has either concealed income or furnished inaccurate particulars. In the present case, there is neither concealment nor inaccuracy. What has happened is nothing more than an inadvertent duplication of a claim, all facts

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

ITA 872/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Sept 2025AY 2017-18

Bench: Hon'Ble Income Tax Appellate Tribunal, Mumbai 'F' Bench M/S Viraj Profiles Private Limited Summary Of Penalty Appeals Sr. No. Nature Of Addition/ Disallowance Ay 2011-12 U/S 271(1)(C) Ay 2013-14 U/S 271(1)(C) Ay 2015-16 U/S 271(1)(C) Ay 2017-18 U/S 271Aab Ay 2018-19 U/S 271Aab (Amt In Inr) Total Addition Made U/S 143(3)

Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

wherein it was held that making a claim which is not accepted in law does not ipso facto amount to furnishing inaccurate particulars of income. It was urged that since the matter was one of interpretation and estimation, no penalty was exigible. 9. The learned CIT(A), after carefully evaluating ... every disallowance or addition. It can be imposed only when there is clear evidence that the assessee has either concealed income or furnished inaccurate particulars. In the present case, there is neither concealment nor inaccuracy. What has happened is nothing more than an inadvertent duplication of a claim, all facts

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are dismissed

ITA 871/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

wherein it was held that making a claim which is not accepted in law does not ipso facto amount to furnishing inaccurate particulars of income. It was urged that since the matter was one of interpretation and estimation, no penalty was exigible. 9. The learned CIT(A), after carefully evaluating ... every disallowance or addition. It can be imposed only when there is clear evidence that the assessee has either concealed income or furnished inaccurate particulars. In the present case, there is neither concealment nor inaccuracy. What has happened is nothing more than an inadvertent duplication of a claim, all facts

Basantilal Tarba, Rajasthan vs. Income Tax Officer, WD-3(1)(2), Surat

In the result, the ground of appeal raised in this appeal is allowed for statistical purposes

ITA 512/SRT/2024[2010-11]Status: DisposedITAT Surat26 Sept 2025AY 2010-11

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.512/Srt/2024 Assessment Year: (2010-11) (Hybrid Hearing) Bansntilal Tarba Income Tax Officer, Ward-3(1)(2), बनाम/ 429/1023, Sundarnagar, Surat, Aaykar Bhavan, Majura Gate, Vs. Ahimsa Circle, Bhilwara, Surat-395 001 Rajasthan- 311 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Afipt 1037 P (Appellant) (Respondent) िनधा"रती की ओर से /Appellant By Shri Prakash Jhunjhunwala, Ca राज" की ओर से/Respondent By Shri Ravinder Sindhu, Cit-Dr सुनवाई की तारीख /Date Of Hearing 23/07/2025 उद्घोषणा की तारीख /Date Of Pronouncement 26/09/2025

Section 144Section 250Section 271(1)(c)Section 274

levy of penalty u/s 271(1)(c) is erroneous since the initiation of penalty, in the assessment order, had been made “for furnishing inaccurate particulars of income”, whereas the penalty has ultimately been levied on altogether different charge of “concealment of income”; 5.0 On facts and circumstances of the case ... since the notice u/s 274 had been issued in mechanical manner without intimating the specific charge of “concealment of income” or “furnishing inaccurate particulars of income”; 6.0 The Ld. AO, before levying the penalty/s 271(1)(c) of Rs.24,05,63,853/- ought to have considered the bona fide explanation

Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

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

ITA 1217/CHNY/2025[2020-21]Status: DisposedITAT Chennai26 Sept 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

provides that only where the AO is satisfied that, the assessee has either concealed the particulars of his income or furnished inaccurate particulars of income that, the AO may direct levy of penalty. In the present case, the AO has sought to levy penalty by holding the assessee ... guilty of furnishing inaccurate particulars of income. In our considered view, in order to do so, it is necessary for the AO to show with material that, there was inaccurate reporting of the particulars of income by the assessee. In the present case, we find that

Redington Distributions Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

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

ITA 1216/CHNY/2025[2018-19]Status: DisposedITAT Chennai26 Sept 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

provides that only where the AO is satisfied that, the assessee has either concealed the particulars of his income or furnished inaccurate particulars of income that, the AO may direct levy of penalty. In the present case, the AO has sought to levy penalty by holding the assessee ... guilty of furnishing inaccurate particulars of income. In our considered view, in order to do so, it is necessary for the AO to show with material that, there was inaccurate reporting of the particulars of income by the assessee. In the present case, we find that

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxn Circle-2(1), Chennai

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

ITA 1215/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Sept 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Ashik Shah, CAFor Respondent: Ms.Anitha, Addl.CIT
Section 133ASection 139Section 148Section 270A(2)Section 271(1)(c)

provides that only where the AO is satisfied that, the assessee has either concealed the particulars of his income or furnished inaccurate particulars of income that, the AO may direct levy of penalty. In the present case, the AO has sought to levy penalty by holding the assessee ... guilty of furnishing inaccurate particulars of income. In our considered view, in order to do so, it is necessary for the AO to show with material that, there was inaccurate reporting of the particulars of income by the assessee. In the present case, we find that

Madison Teamworks Film Promotions and Entertainment Private Limited, Mumbai vs. Deputy Commissioner of Income Tax- 10(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3533/MUM/2025[2013-14]Status: DisposedITAT Mumbai26 Sept 2025AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2013-14 Madison Teamworks Film Deputy Commissioner Of Promotions & Entertainment Income Tax-10(2)(2), Private Limited, Vs. Aayakar Bhavan, 1St Floor, 349 Business Point, M.K. Road, Western Express Highway, Mumbai-400020. Andheri (East), Mumbai-400069. Pan : Aaecm1006B (Appellant) (Respondent) For Assessee : Mr. Siddesh Chaugule & Ms. Manmeet Kaur Saini For Revenue : Shri Annavaram Kosuri, Sr.Dr

For Appellant: Mr. Siddesh Chaugule &For Respondent: Shri Annavaram Kosuri, Sr.DR
Section 143(3)Section 2(22)(e)Section 271(1)(c)Section 274Section 40A(3)

confirmed the addition made on account of Form- 26AS mismatch. The AO accordingly held that the facts clearly indicate that the assessee has furnished inaccurate particulars of income by claiming such inadmissible expenses and by not offering the income on account of deemed dividend and Form-26AS mismatch ... proceedings, the AO has merely referred to the fact the quantum proceedings have attained finality without specifying as to how the assessee has furnished inaccurate particulars of income and has gone ahead and levied the penalty u/s 271(1)(c) of the Act. 16. Further, we find that during

Kamuben Ramanlal Patel, Daman vs. Income Tax Officer, Daman

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

ITA 913/SRT/2024[2012-13]Status: DisposedITAT Surat25 Sept 2025AY 2012-13

Bench: Ms.Suchitra Raghunath Kamble& Shri Bijayananda Prusethआयकरअपीलसं./Ita No.913/Srt/2024 Assessment Year: 2012-13 (Hybrid Hearing) Smt. Kamuben Ramanlal Patel Income Tax Officer, Daman, बनाम/ House No.1, Varkund, Income Tax Department, Jeevanji Vs. Mithanagar, Nani Daman, Hotel Building, Kathiria Road, Daman & Diu-396 210 Nani Daman, Daman & Diu- -396210 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acppk1885N (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri Hemant Suthar, Ca राज"कीओरसे /Respondent By Shriajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 17/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 25/09/2025

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

penalty as required u/s.274 has not specified the charge for the levy of penalty as to for concealment of income or for furnishing inaccurate particulars. Moreover, Ld. AO has levied penalty on dual charges of concealment of income and furnishing of inaccurate particulars of income against the provisions ... LTCG and raising demand of Rs.2,24,80,170/-. Along with this, the AO also initiated penalty proceedings for concealment of income and furnishing inaccurate particulars of income u/s.271(1)(c) of the Act. The assessee had filed an appeal before the CIT(A) against the impugned assessment order

Conwood Construction and Developers Private Limited, Mumbai vs. DCIT Central Circle - 1(4), Mumbai

ITA 4756/MUM/2025[2015-16]Status: DisposedITAT Mumbai25 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 254(1)Section 270(1)Section 271(1)(c)Section 274

Assessing Officer u/s 271(1)(c) of the Income Tax Act, 1961 on 23.03.2022, despite the fact that the appellant has neither furnished inaccurate particulars of its income nor concealed its particulars of income. 2. On the facts and in the circumstances of the appellant company's case ... Officer failed to arrive at satisfaction during the course of assessment proceedings whether the levy of penalty u/s 271(1)(c) was for furnishing inaccurate particulars of income or for concealment of income, which constitutes the basis and foundation of the proceedings for levy of penalty, thereby making the notice

Assistant Commissioner of Income Ta, Jaipur vs. Shri Nath Corporation, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

imposition of penalty when the Assessing Officer is satisfied that the assessee has either; (a) Concealed the particulars of his income; or (b) Furnished inaccurate particulars of such income. 13. It is not the case of furnishing inaccurate particular of income, as in the income-tax return, particulars of income ... Rs.1,80,00,000/- which was admitted during the course of survey. Thus it cannot be said that the assessee had furnished "inaccurate particulars of income" which is not disputed by the Assessing Officer. 6. 1. Further as per Explanation 5A to Section 271(1)(c), penalty is not leviable

Assistant Commissioner of Income Tax, Jaipur vs. Jitendra Kumar Agarwal, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a
Section 133ASection 271(1)(c)

imposition of penalty when the Assessing Officer is satisfied that the assessee has either; (a) Concealed the particulars of his income; or (b) Furnished inaccurate particulars of such income. 13. It is not the case of furnishing inaccurate particular of income, as in the income-tax return, particulars of income ... which was admitted during the course of survey. Thus it cannot be said that the assessee had furnished "inaccurate particulars of income" which is not disputed by the Assessing Officer. 6.1. Further as per Explanation 5A to Section 271(1)(c), penalty is not leviable since the assessee has paid

Assistant Commissioner of Income-Tax, Jaipur vs. Royal Jewellers, Jaipur

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

imposition of penalty when the Assessing Officer is satisfied that the assessee has either; (a) Concealed the particulars of his income; or (b) Furnished inaccurate particulars of such income. 13. It is not the case of furnishing inaccurate particular of income, as in the income-tax return, particulars of income ... Rs.1,80,00,000/- which was admitted during the course of survey. Thus it cannot be said that the assessee had furnished "inaccurate particulars of income" which is not disputed by the Assessing Officer. 6. 1. Further as per Explanation 5A to Section 271(1)(c), penalty is not leviable

Ashok Gurunath Patil, Latur vs. ITO Ward1(1), Latur

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

ITA 594/PUN/2025[2011-12]Status: DisposedITAT Pune24 Sept 2025AY 2011-12

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.594/Pun/2025 धििेंारण वर्ा /Assessment Year: 2011-2012 Ashok Gurunath Patil, Ito, Ward 1(1), Latur A/P Masobavadi, Khed, Nilanga, Latur-413522 Vs. Maharashtra Pan-Bihpp0618K अपीलेंर्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Shri Pratik Sandbhor Department By: Shri Ramnath P Murkunde Date Of Hearing: 24-09-2025 Date Of Pronouncement: 06-10-2025 आदीश/Order Per Dr. Manish Borad:- This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A), Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 21.08.2024 Which Is Arising Out Of Order Passed U/S 271(1)(C) Of The Act Dated 27.02.2018. 2. Registry Has Informed That There Is A Delay Of 123 Days In Filing Of The Appeal. Application For Condonation Of Delay Alongwith Affidavit Has Been Filed & Placed At Page No. 24-26 Of The Appeal Citing The Main Reason For The Delay, That The Assessee Was Not Aware Of Passing Of The Impugned Order As 2 The Tax Consultant Registered The E-Mail Id Of His Younger Son & The E-Mail Account Was Not In Use. After Hearing The Ld. Departmental Representative (Dr) & Perusing The Records We Find That The Sufficient Cause Prevented The Assessee From Filing The Appeal Within The Prescribed Time Limit & The Delay Is Not Intentional. Therefore In The Larger Interest Of Justice & Also Placing Reliance On The Judgement Of Hon’Ble Apex Court In The Case Of Collector, Land Acquisition Vs. Master Katiji & Others(1987) 167 Itr 471(Sc) (Supreme Court) & In The Case Of Inder Singh Vs State Of Madhya Pradesh Judgement Dated 21.03.2025 (2025) Insc 382) We Hereby Condone The Delay Of 123 Days & Admit The Appeal For Adjudication On Merits.

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Ramnath P Murkunde
Section 250Section 271(1)(c)Section 274

much as the penalty has been initiated for concealment of income whereas the penalty has been levied for furnishing inaccurate particulars of income 4. On the facts and in the circumstances of the case and in law the penalty order u/s 271(1)(c) is invalid

Allied Construction Company, Malad vs. Income Tax Officer - 30 (1) (1), Bandra

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

ITA 4121/MUM/2025[2012-13]Status: DisposedITAT Mumbai23 Sept 2025AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhanassessment Year : 2012-13 M/S. Allied Construction Ito-30(1)(1), Company, C-13, 5Th Floor, 4&5, Sai Zarukha Vs. Pratyakshakar Bhavan, B.J. Patel Road, Bandra East, Malad (West), Mumbai-400051. Mumbai-400064. Pan : Aapfa8255N (Appellant) (Respondent) Assessee By : Shri Jose Pulikkoden Revenue By : Shri Surendra Mohan, Sr.Dr

For Appellant: Shri Jose PulikkodenFor Respondent: Shri Surendra Mohan, Sr.DR
Section 133ASection 271(1)(c)

reading of the assessment order reveals that the AO himself was uncertain as to whether the assessee had concealed particulars of income or furnished inaccurate particulars of income and this uncertainty is manifest from the contradictory findings recorded by the AO at different stages of the proceedings and our reference ... drawn to the penalty order dt. 26-03-2018, wherein the AO concludes in paragraphs No. 6 and 8 that the assessee has furnished inaccurate particulars of income, without reconciling or withdrawing the earlier finding of concealment. It was submitted that where the AO is himself unsure of the precise

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2006/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

Rs.59,18,00,000/- (amount received from 636 investors of AMR customers) and further initiated up penalty U/s 271 (1)(c) for furnishing inaccurate particulars of income.” 5. Thereafter, the assessee has also taken additional grounds of appeal, wherein the assessee has challenged the proceedings initiated by issue of notice

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2005/DEL/2025[2015-16]Status: DisposedITAT Delhi22 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

Rs.59,18,00,000/- (amount received from 636 investors of AMR customers) and further initiated up penalty U/s 271 (1)(c) for furnishing inaccurate particulars of income.” 5. Thereafter, the assessee has also taken additional grounds of appeal, wherein the assessee has challenged the proceedings initiated by issue of notice

Dialnet Communications Ltd., New Delhi vs. ITO Ward - 7(3), New Delhi

In the result the appeal of the assessee is allowed

ITA 7885/DEL/2019[2015-16]Status: DisposedITAT Delhi19 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaassessment Year: 2015-16 Dial Net Communications Ltd., Vs Income Tax Officer, C-31, Ground Floor, Greater Ward-7(3), New Delhi. Kailash, Part-I, Delhi-110048. Pan: Aabcd 5472 D Appellant Respondent

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

under section 271(1)(c) did not specifically state as to whether assessee was guilty of concealing particulars of his income or had furnished inaccurate particulars of income. Hence, the impugned penalty was invalid and same was to be set aside. The adjudication of Hon’ble Court was as under ... Section 143(3) of the Act, the cash deposits would not have come to light and therefore, rendered a finding that the assessee furnished inaccurate particulars. 25. This finding of the Assessing Officer is incorrect because while completing the assessment under Section 143(3) of the Act, there