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“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

Assistant Commissioner of Income Tax, Dehradun vs. Seabird Exploration Fz-Llc, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 134/DDN/2024[2012-13]Status: DisposedITAT Dehradun18 Feb 2026AY 2012-13

Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)Section 44B

Products (P) Ltd. (supra) has held that Section 271(1)(c) applies where the assessee "has concealed the particulars of his income or furnished inaccurate particulars of such income". As regards the furnishing of inaccurate particulars, it was found by the Hon'ble Supreme Court that no information given ... Apex Court observing that by no stretch of imagination can the making of an incorrect claim in law tantamount to furnishing inaccurate particulars. It was held that a mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding

M/S. R R Industries Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

ITA 2742/CHNY/2025[2009-10]Status: DisposedITAT Chennai18 Feb 2026AY 2009-10

Bench: Shri Aby T. Varkey & Ms. Padmavathy. Sआयकर अपील सं./Ita Nos.2741 To 2743/Chny/2025 निर्धारणवर्ष/Assessment Year: 2008-09 To 2010-11 M/S. Rr Industries Ltd., No.94/95, Thiru Vi Ka Industrial Estate, Guindy, Chennai-600 032. [Pan: Aaacr 3594 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Dcit, Central Circle-1(4), Chennai. (प्रत्यर्थी/Respondent) : Mr.M.K. Rangaswamy, Ca : Ms.R. Anitha, Addl.Cit : 11.02.2026 : 18.02.2026 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), (Hereinafter In Short `The Ld.Cit(A)'), Chennai-18, Dated 07.08.2025, For The Assessment Year (Hereinafter In Short `Ay') 2008-09 To 2010-11 Confirming The Penalty- Imposed U/S.271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act'). :: 2 ::

Section 10ASection 143(3)Section 153CSection 2Section 271(1)(c)Section 274

which later concluded on 24.03.2020 by the AO passing the order imposing penalty on the ground that the assessee had furnished inaccurate particulars of income with regard to the deduction of Rs.90,37,808/-claimed u/s 10A of the Act and thereby levied penalty u/s 271(1)(c) amounting ... what specific fault/infraction assessee should defend against the proposed penalty 271(1)(c) i.e. whether the assessee furnished inaccurate particulars of his income, or concealed the particulars of his income, without which the impugned notice is bad in law for being vague/arbitrary and not issued without application of mind

Sangeeta Golchha, Raipur vs. ITO-4(1), Raipur

In the result, appeal of the assessee is allowed

ITA 788/RPR/2025[2014-15]Status: DisposedITAT Raipur17 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.788/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Sangeeta Golchha 9/532, Behind Mahavir Bhawan, Budhapara, Raipur-492 001 (C.G.) Pan: Adcpg6259Q

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 10(38)Section 271(1)(c)

income, he is absolved from penalty.” 3. In this factual background, the A.O levied penalty u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income on the ground that surrendering of income by the assessee and full and true disclosure of such income was not done ... penalty. The A.O has not made out any case for imposition of penalty as to how and in what manner the assesse had furnished inaccurate particulars of income. Accordingly, we do not find any infirmity in the findings of the Ld. CIT(Appeals)/NFAC which is hereby upheld

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT-2(3)(1), Mumbai

ITA 7704/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

quantum appeal. 1.3. The Id. CIT(A) further erred in confirming the levy of penalty u/s. 271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account of alleged concealment of income alone. 1.4. The Appellant prays that

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT- 2(3)(1), Mumbai

ITA 7703/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

quantum appeal. 1.3. The Id. CIT(A) further erred in confirming the levy of penalty u/s. 271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account of alleged concealment of income alone. 1.4. The Appellant prays that

Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam, Cuddapah vs. ITO., Exemption Ward, Tirupathi

In the result, the appeal of the assessee in ITA No

ITA 1164/HYD/2025[2016-17]Status: DisposedITAT Hyderabad13 Feb 2026AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1164/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer Brahmendra Swamula Vari Exemption Ward, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) आ.अपी.सं /Ita No.2287/Hyd/2025 ("नधा"रण वष"/Assessment Year: 2016-17) Srimad Virat Pottuluri Veera Vs. Income Tax Officer, Brahmendra Swamula Vari Exemption Ward, Chittoor, Mattam, Kadapa. Tirupati. Pan: Aagts2599Q (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri Ravindra Chenji, Advocate (Through Hybrid Mode) राज" व "वारा/Revenue By:: Ms. Payal Gupta, Sr.Ar सुनवाई क" तार"ख/Date Of Hearing: 09/02/2026 घोषणा क" तार"ख/Pronouncement: 13/02/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: The Captioned Appeals Are Filed By Srimad Virat Pottuluri Veera Brahmendra Swamula Vari Mattam (“The Assessee”), Feeling Aggrieved By The

For Appellant: Shri Ravindra Chenji, AdvocateFor Respondent: : Ms. Payal Gupta, Sr.AR

learned senior counsel for the assessee has submitted that the satisfaction as to the assessee having concealed the particulars of his income or furnished inaccurate particulars of such income is to be arrived at by the Assessing Officer during the Page 7 of 12 ITA No.1164 & 2287/Hyd/2025 Srimad Virat Pottuluri ... 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 of the Assessing

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Nutech Metal), Mumbai vs. Income Tax Officer Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8693/MUM/2025[2011-12]Status: DisposedITAT Mumbai13 Feb 2026AY 2011-12

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

additions made on account of alleged bogus purchases are purely on the basis of estimation, whether the assessee can be accused of furnishing inaccurate particulars of income to be visited with penalty u/s. 271(1)(c) of the Act. In this context, we may refer to the decision ... reach to a conclusion that the assessee be held liable for a penalty, on the count of furnishing inaccurate particulars or there was concealment of income, is the issue. (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO 16. It is well settled that the condition precedent

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Nutech Metal), Mumbai vs. Income Tax Office Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8692/MUM/2025[2010-11]Status: DisposedITAT Mumbai13 Feb 2026AY 2010-11

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

additions made on account of alleged bogus purchases are purely on the basis of estimation, whether the assessee can be accused of furnishing inaccurate particulars of income to be visited with penalty u/s. 271(1)(c) of the Act. In this context, we may refer to the decision ... reach to a conclusion that the assessee be held liable for a penalty, on the count of furnishing inaccurate particulars or there was concealment of income, is the issue. (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO 16. It is well settled that the condition precedent

Sh. Ratnaram Kohlaram Chaudary (Prop. of M/S. Netech Metal), Mumbai vs. Income Tax Office Ward 19(3)(1), Mumbai

In the result, the appeals are allowed

ITA 8691/MUM/2025[2009-10]Status: DisposedITAT Mumbai13 Feb 2026AY 2009-10

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Ravi GuptaFor Respondent: Shri Annavaram Kosuri, Sr. AR
Section 139Section 143(1)Section 147Section 271(1)(c)Section 274

additions made on account of alleged bogus purchases are purely on the basis of estimation, whether the assessee can be accused of furnishing inaccurate particulars of income to be visited with penalty u/s. 271(1)(c) of the Act. In this context, we may refer to the decision ... reach to a conclusion that the assessee be held liable for a penalty, on the count of furnishing inaccurate particulars or there was concealment of income, is the issue. (A.Ys. 2009-10 to 2011-12) Shri Ratnaram Kohlaram Chaudhary vs. ITO 16. It is well settled that the condition precedent

Rasila Lalitkumar Cholera, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 7544/MUM/2025[2011-12]Status: DisposedITAT Mumbai13 Feb 2026AY 2011-12

Bench: Smt. Beena Pillai ()

Section 143(1)Section 147Section 148Section 68Section 69Section 69C

u/s.68 of I.T. Act, 1961. Penalty proceedings u/s. 271(1)(c) r.w.s. 274 of the Income Tax Act, 1961, are separately initiated for furnishing inaccurate particulars of income. 12. Further, it has been admitted by various hawala operators in similar kind of cases that they were providing the accommodation entries ... income of the assessee. Penalty proceedings u/s. 271(1)(c) r.w.s. 274 of the Income Tax Act, 1961, are separately initiated for furnishing inaccurate particulars of income.” Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before the Ld.CIT(A). 5 I.T.A. No. 7544/Mum/2025 3. Before

Manish Kantilal Haria, Mumbai vs. Income Tax Officer International Tax Ward 2 (2) (1), Mumbai

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

ITA 6187/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Feb 2026AY 2020-21

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Pankaj Chag (virtually appeared)For Respondent: Shri Pravin Salunkhe, Sr. DR
Section 250

Para 3 of assessment order is mentioned that "Penalty proceedings under section 270A of the I.T Act, 1961 are initiated separately “for furnishing inaccurate particulars of income." Thus, reason for initiation of penalty proceeding is "furnishing inaccurate particulars of income." There are no wordings in s. 270A that penalty proceedings ... initiated for furnishing inaccurate particulars of income. Thus, it can be said that penalty proceedings are not initiated as per provisions of law. Initiation of penalty proceedings be dropped.” 5. We have considered the submissions of both sides and perused the material available on record. In the present case

Pba Infrastructure Limited, Mumbai vs. DCIT, Central Circle 5(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 4212/MUM/2025[2003-04]Status: DisposedITAT Mumbai13 Feb 2026AY 2003-04

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR a/w
Section 115JSection 143(3)Section 271Section 271(1)(c)

Under clause (iii) of sub-section (1) of section 271 of the Act, penalty for concealment of income or furnishing inaccurate particulars of income is determined based on the "amount of tax sought to be evaded" which has been defined inter-alia, as the difference between

Pba Infrastructure Limited, Mumbai vs. DCIT, Central Circle 5(1), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 4211/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR a/w
Section 115JSection 143(3)Section 271Section 271(1)(c)

Under clause (iii) of sub-section (1) of section 271 of the Act, penalty for concealment of income or furnishing inaccurate particulars of income is determined based on the "amount of tax sought to be evaded" which has been defined inter-alia, as the difference between

Neysa Jewllery Ltd, Mumbai vs. DCIT, Cir-2(3)(1), Mumbai

In the result, the grounds of appeal raised by the assessee are allowed

ITA 5934/MUM/2025[2005-06]Status: DisposedITAT Mumbai12 Feb 2026AY 2005-06

Bench: Shri Pawan Singh& Shri Arun Khodpia(Physical Hearing)

Section 10ASection 133ASection 143(3)Section 254(1)Section 271(1)(c)

further appeal. The AO while passing the assessment order initiated penalty proceeding under section 271(1)(c) by invoking Explanation-1 thereto for furnishing inaccurate particulars of income. Notice under section 271(1)(c) was issued vide notice dated 29.10.2007. In response to show cause notice, the assessee filed ... income. Fifthly, no addition was made in the assessment completed in response to revised return of income; hence, there is no occasion for furnishing inaccurate particulars ITA 5934/Mum/2025 (AY 2005-06) Neysa Jewellery Limited of income. To support their view, the assessee relied on various case laws. The reply

Emmbros Autocomp Limited, Baddi vs. Asstt. Commissioner of Income Tax, Parwanoo

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 1172/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh11 Feb 2026AY 2013-14

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1172/Chd/2024 "नधा"रण वष" / Assessment Year : 2013-14 M/S Emmbros Autocomp The Acit, बनाम Limited, Village Katha, Circle, Baddi, Parwanoo Vs. Distt. Solan 173220 "थायी लेखा सं./ Pan No: Aaace3489Q अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Raman Tiwari, Ca राज"व क" ओर से/ Revenue By : Sh. Vivek Varadhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 09.02.2026 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.02.2026 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 24.09.2024 Passed By The Ld. Commissioner Of Income Tax, Exemptions [‘(Cit(A)’]

For Appellant: Sh. Raman Tiwari, CAFor Respondent: Sh. Vivek Varadhan, Addl. CIT, Sr.DR
Section 143(3)Section 271(1)Section 271(1)(C)Section 801CSection 80I

confirmed the penalty imposed under section 271(1)(C) of the Income Tax Act, 1961 amounting to Rs. 27,85,000/ for furnishing inaccurate particulars of Income in respect of claim of deduction under section 80IC whereas the issue itself was debatable at the time of filing of return. Hence ... Appeals), NFAC, Delhi has not appreciated the facts of the case that penalty under section 271(1) has beer initiated on account of furnishing inaccurate particulars of Income in respect of claim of deduction under section 801C whereas the issue itself was debatable at the time of filing of return

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

invited our attention to the SCN, wherein the Ld. AO has merely stated that the assessee has concealed the particulars of income or furnished inaccurate particulars of such income. According to the Ld. AR, the SCN suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion ... above we find that, the SCN clearly shows that the Ld. AO has used the expression “concealed the particulars of income or furnished inaccurate particulars of such income” without striking off the irrelevant portion. The law is now well settled that penalty under section

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

invited our attention to the SCN, wherein the Ld. AO has merely stated that the assessee has concealed the particulars of income or furnished inaccurate particulars of such income. According to the Ld. AR, the SCN suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion ... above we find that, the SCN clearly shows that the Ld. AO has used the expression “concealed the particulars of income or furnished inaccurate particulars of such income” without striking off the irrelevant portion. The law is now well settled that penalty under section

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

invited our attention to the SCN, wherein the Ld. AO has merely stated that the assessee has concealed the particulars of income or furnished inaccurate particulars of such income. According to the Ld. AR, the SCN suffers from vagueness, as the Ld. AO did not strike off the irrelevant portion ... above we find that, the SCN clearly shows that the Ld. AO has used the expression “concealed the particulars of income or furnished inaccurate particulars of such income” without striking off the irrelevant portion. The law is now well settled that penalty under section

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

Assessing Officer has reproduced the standard printed format wherein the relevant portion reads as under: “have concealed the particulars of your income or furnished inaccurate particulars of such income.” 9. The Ld. AR submitted that in the said notice, the Assessing Officer has not struck off the inapplicable limb ... section 271(1)(c), namely, whether the penalty proceedings were initiated for “concealment of particulars of income” or for “furnishing inaccurate particulars of income”. Both the limbs remain intact in the notice and no specific charge has been indicated. The Ld. AR further submitted that though in the assessment order

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

Assessing Officer has reproduced the standard printed format wherein the relevant portion reads as under: “have concealed the particulars of your income or furnished inaccurate particulars of such income.” 9. The Ld. AR submitted that in the said notice, the Assessing Officer has not struck off the inapplicable limb ... section 271(1)(c), namely, whether the penalty proceedings were initiated for “concealment of particulars of income” or for “furnishing inaccurate particulars of income”. Both the limbs remain intact in the notice and no specific charge has been indicated. The Ld. AR further submitted that though in the assessment order