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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

Subodh Gupta, Delhi vs. ACIT, New Delhi

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

ITA 1264/DEL/2017[2009-10]Status: DisposedITAT Delhi31 Jan 2025AY 2009-10

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri Vizay B. Vasanta, CIT-DR
Section 143(2)Section 143(3)Section 234B

facts and in the circumstances of the case and in law, the Ld. AO has erred in initiating penalty for furnishing inaccurate particulars of income. The Appellant prays for leave to add, alter, rescind from or withdraw any of the above grounds of appeal at or before the time

Falguni S. Mehta, Ahmedabad vs. The ITO, Ward-1(2)(1), Vadodara

In the result, the appeal of the assessee is allowed

ITA 1603/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad30 Jan 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra P. Sinha

For Respondent: Shri S K Agal, Sr. DR
Section 143(3)Section 250Section 271(1)(c)

explain away its conduct. The question is whether the assessee has offered any explanation for concealment of particulars of income or furnishing inaccurate particulars of income. Explanation to section 271(1)(c) raises a presumption of concealment when a difference is noticed by the AO, between reported and assessed income ... penalty proceedings u/s.271(1)(c) of the Act, there is no clarity whether penalty proceedings have been initiated for “concealment of income" or furnishing “inaccurate particulars of income" and for this reason as well as, the penalty order is liable to be set-aside. 7. In response

Fantacy Creations, Kolkata vs. D.C.I.T., Circle - 25, Kolkata

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

ITA 1449/KOL/2024[2006-2007]Status: DisposedITAT Kolkata30 Jan 2025AY 2006-2007

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

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

Addition of Rs. 4,81,421/- on account of unexplained money. Penalty proceedings were initiated for concealment of income as well as furnishing inaccurate particulars of income. Penalty order u/s 271(1)(c ) of the act was passed on 30.06.2017 for concealment of particulars of income as well as furnishing ... charge which was not appropriate. The Ld. Counsel submits that the notice reveals that we have concealed the particulars of your income or furnished inaccurate particulars of your income. The Ld. Counsel submits that there is no specific charges against the assessee in the said notice, hence the notice

Joint Commissioner of Income Tax (OSD)-3(4), Mumbai vs. Ambuja Cements Limited, Mumbai

ITA 312/MUM/2024[2011-12]Status: DisposedITAT Mumbai30 Jan 2025AY 2011-12

Bench: the Assessing Officer to set out his defence against levy of penalty?." 3. The relevant facts in brief are that the Assessee, a public Limited company engaged, inter alia, in manufactured and sale of cement, filed original return of income for the Assessment Year 2011–2012 on 30/11/2011. Thereafter, the Assessee filed a revised return of income on 27/11/2012, which was selected for regular scrutiny.

For Appellant: Shri Vartik ChoksiFor Respondent: Shri Ram Krishn Kedia
Section 143(3)Section 250Section 263Section 271(1)(c)Section 274

Income Tax Act, 1961 on technical ground without Assessment Year 2011-2012 considering that in the assessment order penalty was initiated for furnishing inaccurate particulars of income and in the penalty order also the penalty was imposed for the same default. 2. Whether on the facts and circumstances ... making addition of INR.3.98 Crores by disallowing the deduction claimed in respect of Provisions for Mines Reclamation Expenses and initiated penalty proceeding for furnishing inaccurate particulars of income under Section 271(1)(c) of the Act. 4. During the penalty proceedings, the Assessee was asked to show cause

Khilan N. Patel (HUF), Surat vs. The DCIT, Circle-2(3), Surat

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

ITA 429/SRT/2024[2016-17]Status: DisposedITAT Surat29 Jan 2025AY 2016-17

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.429/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) Khilan N. Patel (Huf), Vs. The Dcit, 6/2201, Nagarsheri, Mahidharpura, Circle – 2(3), Surat – 395003 (Gujarat) Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakhk6987L (Appellant) (Respondent) Appellant By Shri Akshay M. Modi, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 27/01/2025 Date Of Pronouncement 29/01/2025

Section 10(34)Section 143(3)Section 250Section 271(1)(c)Section 68

later invested in share transactions. Hence, Rs.41,00,000/- was added u/s 68 and penalty u/s 271(1)(c) were initiated for furnishing inaccurate particulars of income. The assessee had also disclosed short-term capital gain (STCG) of Rs.32,79,845/-. As the assessee had entered into large volume ... taking actual delivery, the amount shown as “capital gain” was treated as “business income”. Penalty proceedings u/s 271(1)(c) were initiated for furnishing inaccurate particulars of income. 4. Aggrieved by the order of AO, the assessee filed this appeal before the CIT(A). The CIT(A) had issued

Ch Rama Rao, Vijayawada vs. Income Tax Officer, Ward-3(4), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 345/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam28 Jan 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble Vice- & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.344 & 345/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2015-16 2016-17) Ch Rama Rao V. Income Tax Officer - Ward – 3(4) C.R. Building 4-99, Ramavarappadu Vijayawada- 520002 Vijayawada – 521108 Andhra Pradesh Andhra Pradesh [Pan: Aacfc0545L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 148Section 250Section 271(1)(c)

since there were withdrawals of funds by the partners over and above the capital. This by itself cannot be termed as furnishing inaccurate particulars. 5. For these and other reasons that are to be urged at the time of hearing, the appellant prays that the penalty imposed is liable ... failure of the assessee to disallow the interest, in our opinion it leads to the conclusion that there is concealment of income by furnishing inaccurate particulars by the assessee. We therefore have no hesitation to confirm the order of the Ld. CIT(A) as there is no infirmity

Ch Rama Rao, Vijayawada vs. Income Tax Officer, Ward-3(4), Vijayawada

Appeal of the assessee is dismissed

ITA 344/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 Jan 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble Vice-

Section 142(1)Section 148Section 250Section 271(1)(c)

since there were withdrawals of funds by the partners over and above the capital. This by itself cannot be termed as furnishing inaccurate particulars. 5. For these and other reasons that are to be urged at the time of hearing, the appellant prays that the penalty imposed is liable ... failure of the assessee to disallow the interest, in our opinion it leads to the conclusion that there is concealment of income by furnishing inaccurate particulars by the assessee. We therefore have no hesitation to confirm the order of the Ld. CIT(A) as there is no infirmity

The Kangra Central Cooperative Bank Limited, Dharamshala vs. Deputy Commissioner of Income Tax, Palampur

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

ITA 805/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh28 Jan 2025AY 2013-14
For Respondent: Shri Ashwani Kumar, C.A
Section 143(3)Section 250Section 271(1)(c)Section 274Section 36(1)(viia)

uphold the action of the Ld. Assessing Officer in levying a penalty of Rs. 66,38,400/- for alleged concealment of income by furnishing inaccurate particulars of income, without considering the facts and circumstances of the case and the legal position in as much as no such penalty was exigible ... separately, the penalty proceedings were initiated under section 271(1)(c) of the Act for concealment of income by furnishing inaccurate particulars of income by issuing a notice dt. 05/03/2014 under section 274 r.w.s 271 of the Act. 5. The assessee carried the matter in appeal before

The Kangra Central Cooperative Bank Limited, Dharamshala vs. Deputy Commissioner of Income Tax, Palampur

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

ITA 804/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh28 Jan 2025AY 2012-13

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(3)Section 250Section 271(1)(c)Section 274Section 36(1)(viia)

uphold the action of the Ld. Assessing Officer in levying a penalty of Rs. 66,38,400/- for alleged concealment of income by furnishing inaccurate particulars of income, without considering the facts and circumstances of the case and the legal position in as much as no such penalty was exigible ... separately, the penalty proceedings were initiated under section 271(1)(c) of the Act for concealment of income by furnishing inaccurate particulars of income by issuing a notice dt. 05/03/2014 under section 274 r.w.s 271 of the Act. 5. The assessee carried the matter in appeal before

Escee Traders Pvt. Ltd. (Formerly Known As Satkriti Properties Pvt. Ltd.), Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal of assessee is allowed

ITA 1752/KOL/2024[2012-2013]Status: DisposedITAT Kolkata28 Jan 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1752/Kol/2024 Assessment Year: 2012-13 Escee Traders Pvt. Ltd (Formerly Known As Satkriti Properties Pvt. Ltd.) ….....Appellant 12Th Floor, Unit 12B, Unimark Asian, 52/1, Shakespeare Sarani, Kolkata – 700017. [Pan: Aancs7043M] Vs. Ito, Ward-5(1), Kolkata……….……….…............................…..…..... Respondent Appearances By: Shri R. C. Jhawer, Fca, Appeared On Behalf Of The Appellant. Smt. Rama Choudhary, Jcit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 14, 2025 Date Of Pronouncing The Order : January 28, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Pertaining To Assessment Year 2012-13 Against The Order Dated 21.06.2024 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’) Which In Turn Arises Out Of A Penalty Order Passed By The Assessing Officer U/S 271(1)(C) Of The Act Dated 26.03.2022. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Declaring Total Income Of Rs.19,81,896/-. The Case Of The Assessee Was Reopened U/S 147 Of The Act Based On Information Received Regarding Bogus Ltcg On Sale Of Shares Of Banas Finance Ltd. It Was Alleged That The Assessee Purchased 55,000 Shares For Rs.30,11,800/- & Sold Them For Rs.10,05,950/- Booking A Loss Of Rs.20,05,850/-. During The Assessment Proceedings, It Was Concluded

Section 143(3)Section 147Section 250Section 271(1)(c)

also mentioned in his order that penalty proceedings u/s 271(1)(c) of the Act was separately initiated for furnishing inaccurate particulars of income and the Assessing Officer thereafter passed a penalty order u/s 271(1)(c) of the Act by levying penalty of Rs.6,19,809/- upon the assessee ... evidence on record to prove its grounds of appeal that the finding of the AO was not correct. Hence, the appellant has furnished inaccurate particulars of income within the meaning of section 271(1)(c) read with Explanation thereto. Hence, the penalty levied by the AO is confirmed

DCIT - 1(1)(2), Mumbai vs. Housing Development Finance Corporartion Ltd., Mumbai

ITA 2862/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Jan 2025AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advoca

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Muthurathinam, Tiruppur vs. ITO, Ward-1(2), Tiruppur

In the result, appeal filed by the assessee is allowed

ITA 2656/CHNY/2024[2013-14]Status: DisposedITAT Chennai27 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2656/Chny/2024 (िनधा"रणवष" / Assessment Year: 2013-2014) Muthurathinam, Vs. The Income Tax Officer, 27/29, Kumarappapuram, Ward 1(2) 1St Street, Rayapuram Extension, Tirupur. Tirupur 641 601. [Pan: Avypm 0862D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, (Erode) Advocate By Virtual. ""यथ" क" ओर से /Respondent By : Ms. Anitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 31.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.01.2025 आदेश / O R D E R Per Manu Kumar Giri () This Penalty Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21.08.2024 For Assessment Year 2013-14. 2. The Issue Sought To Be Urged By The Assessee In This Appeal Is Whether The Cit(A) Was Justified In Upholding The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 ["Act"] By Ignoring The Fact That The Assessing Officer (‘Ao’ In Short) In Assessment Order Dated 28.09.2021 Has Satisfied That Penalty Proceeding Is Being Initiated Separately For “Furnishing Of Inaccurate Particulars Of Such Income” Where As Penalty Order U/S 271(1)(C) Dated 04.01.2022 Levied Penalty For “Concealment Of Income”, Although In The Notice Under Section 274 Read With Section 271(1) (C), The Ao Has Marked The Specified Limb As “That You Have Furnished Inaccurate Particulars Of Such Income”.

For Appellant: Shri. S. Sridhar, (Erode) Advocate by virtualFor Respondent: Ms. Anitha, IRS, Addl. CIT
Section 143(2)Section 143(3)Section 148Section 151Section 271Section 271(1)Section 271(1)(c)Section 274Section 44A

notice under Section 274 read with Section 271(1) (c), the AO has marked the specified limb as “that you have furnished inaccurate particulars of such income”. 3. For the sake of convenience, it will be apposite to refer to the facts of the case. Shorn of all necessary details ... claim as "Income from Other Sources" in the return of income. Penalty proceedings under section 271(1)(c) were separately initiated for 'furnishing. inaccurate particulars of such income vide notice dated 28.09.2021 and an order under section 271(1)(c) dated 04.01.2022 was passed levying minimum penalty impossible of Rs.5

Flair Exports Pvt. Ltd., New Delhi vs. ACIT Circle-9(1), New Delhi

The appeal of the assessee is allowed

ITA 7091/DEL/2019[2015-16]Status: DisposedITAT Delhi24 Jan 2025AY 2015-16

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri R.K. Kapoor, CAFor Respondent: Shri Rajesh Kumar Dhanesta, SR. DR
Section 142(1)Section 143(2)Section 43(5)

added back to the total income of the assessee company. The undersigned is satisfied that the assessee company has concealed income by furnishing inaccurate particulars of income, and hence penalty proceedings u/s 271(1)(c) are initiated separately. Addition of Rs. 56,74,032” 8. The Ld. CIT(A) upheld

Dey Trading Co., Kolkata vs. I.T.O., Ward - 49(3), Kolkata

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

ITA 2157/KOL/2024[2011-2012]Status: DisposedITAT Kolkata23 Jan 2025AY 2011-2012

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(3)Section 251Section 271Section 271(1)Section 271(1)(c)Section 274Section 69

issued did not mention the amount of concealment rather it has only been mentioned that “you have concealed the particulars of your income……….” Furnished inaccurate particulars of income. The Ld. Counsel cited a decision passed by ITAT, Mumbai in Jatin Enterprises vs. ACIT, 3 I.T.A. No. 2157/Kol/2024 Assessment Year ... I.T.A. No. 2157/Kol/2024 Assessment Year: 2011-12 Dey Trading Co. as, “have Concealed the particulars of your income or …….. Furnished inaccurate particulars of such income.” The Assessing Officer has not struck off irrelevant clauses in the notice. The Hon’ble Jurisdictional High Court in the case of Mohd. Farhan

Joel Jewellery Works, Thrissur vs. ITO WD-2(2), Thrissur

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

ITA 555/COCH/2024[2016-17]Status: DisposedITAT Cochin22 Jan 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2016-17 Joel Jewellery Works .......... Appellant Chiyaram P.O., Thrissur 680006 [Pan: Aagfj1072R] Vs. The Income Tax Officer .......... Respondent Ward - 2(2), Thrissur Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 17.01.2025 Date Of Pronouncement: 22.01.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 29.12.2023 For Assessment Year (Ay) 2016-17. 2. Brief Facts Of The Case Are That The Appellant Is A Partnership Firm Engaged In The Business Of Jewellery. The Return Of Income For Ay 2016-17 Was Filed On 26.01.2017 Disclosing Total Income Of Rs. 5,00,140/-. Against The Said Return Of Income, The Assessment Was Completed By The Income Tax Officer, Ward 2(2), Thrissur (Hereinafter Called "The Ao") Vide Order Dated 10.12.2018 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The Act) At A Total Income

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 271(1)(c)Section 274Section 40

source. The AO also initiated penalty proceedings u/s. 271(1)(c) of the Act by alleging that the appellant is guilty of furnishing inaccurate particulars of income. There is nothing on record to show that the appellant contested the addition before the appellate forum. The appellant responded to the show ... appellant filed detailed explanation stating that the appellant cooperated with the Department in the assessment proceedings and has not furnished inaccurate particulars of income. However, the AO proceeded with levy of penalty of Rs. 12,58,100/- vie order dated 26.06.2019. 3. Being aggrieved, an appeal was filed before

Si Shraddha Realtors, Mumbai, Maharashtra, India vs. ITO 32(3)(3), Mumbai, India

ITA 2912/MUM/2024[2013-14]Status: DisposedITAT Mumbai22 Jan 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawal

For Appellant: Shri Ajay R Singh, Ld. A.R. &For Respondent: Shri Nayanjyoti Nath, Ld. Sr. D.R
Section 132Section 132(4)Section 133(6)Section 143(2)Section 250

total income of the assessee as unexplained cash credit. Penalty proceedings u/s 271(1)(c) of the act are separately initiated for furnishing inaccurate particulars and concealment of income.” 6. The AO also disallowed the interest expenditure of Rs.8,63,672/- as claimed by the Assessee and added ... disallowed and added to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the act are separately initiated for furnishing inaccurate particulars and concealment of income.” 7. The Assessee, being aggrieved, challenged the said additions before the Ld. Commissioner, who more or less on the same

Sai Shraddha Realtors, Mumbai vs. Income Tax Officer 32(3)(2)), Mumbai

In the result, in view of our decision in ITA

ITA 2909/MUM/2024[2014-15]Status: DisposedITAT Mumbai22 Jan 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawal

For Appellant: Shri Ajay R Singh, Ld. A.R. &For Respondent: Shri Nayanjyoti Nath, Ld. Sr. D.R
Section 132Section 132(4)Section 143(2)Section 250

total income of the assessee as unexplained cash credit. Penalty proceedings u/s 271(1)(c) of the act are separately initiated for furnishing inaccurate particulars and concealment of income.” 6. The AO also disallowed the interest expenditure of Rs.8,63,672/- as claimed by the Assessee and added ... disallowed and added to the total income of the assessee. Penalty proceedings u/s 271(1)(c) of the act are separately initiated for furnishing inaccurate particulars and concealment of income.” 7. The Assessee, being aggrieved, challenged the said additions before the Ld. Commissioner, who more or less on the same

Suburban Builders Private Limited, Mumbai vs. ITO-8(2)(4), Mumbai

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 1135/MUM/2024[2007-08]Status: DisposedITAT Mumbai22 Jan 2025AY 2007-08

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhriassessment Year: 2007-08

For Appellant: Shri Sanjay Kapadia, Ld. A.RFor Respondent: Ms. Monika H. Pande, Ld. Sr. DR
Section 143(3)Section 148Section 250

section 68 of the Act. Penalty proceedings u/s 271(1)(c) of the Act are initiated for concealing the particulars of income by furnishing inaccurate particulars of income.” 3. The assessee being aggrieved challenged the reopening of the case u/s 147 of the Act and the addition on merit

Mrs. Neeta Gupta, New Delhi vs. ACIT, New Delhi

Appeals are allowed in above terms

ITA 6416/DEL/2016[2009-10]Status: DisposedITAT Delhi22 Jan 2025AY 2009-10

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Dhiraj Kumar Jain, Sr. DR
Section 1Section 148Section 251(1)

6416/Del/2016 are directed against the Assessing Officer’s and the CIT(A)’s respective actions holding her to have concealed and furnished inaccurate particulars of income regarding the claim of cost of acquisition ITA Nos. 2186 & 6416/Del/2016 Neeta Gupta and the one resulting in enhancement after treatment of long term ... STCG over and above the finding of the AO. Therefore, the penalty proceedings u/s 271(1)(c), for concealment of income and furnishing inaccurate particulars of income in respect of income of Rs.53,82,812/- and change of LTCG to STCG within the meaning of explanation

Mrs. Neeta Gupta, New Delhi vs. ITO, New Delhi

Appeals are allowed in above terms

ITA 2186/DEL/2016[2006-07]Status: DisposedITAT Delhi22 Jan 2025AY 2006-07

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Dhiraj Kumar Jain, Sr. DR
Section 1Section 148Section 251(1)

6416/Del/2016 are directed against the Assessing Officer’s and the CIT(A)’s respective actions holding her to have concealed and furnished inaccurate particulars of income regarding the claim of cost of acquisition ITA Nos. 2186 & 6416/Del/2016 Neeta Gupta and the one resulting in enhancement after treatment of long term ... STCG over and above the finding of the AO. Therefore, the penalty proceedings u/s 271(1)(c), for concealment of income and furnishing inaccurate particulars of income in respect of income of Rs.53,82,812/- and change of LTCG to STCG within the meaning of explanation