“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

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 1937/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Jan 2026AY 2009-10

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Assessee by

Section 143(1)Section 271Section 271(1)(c)

instant case mens rea is proved from the conduct of the assessee and that the assessee has concealed the income by furnishing inaccurate particulars of income and committed default u/s 271(1)(c) of the Act and this is a fit case for levy of penalty ... conclusion that the disputed income represented income, and that the assessee had consciously concealed the particulars of his income or had deliberately furnished inaccurate particulars. 36. In view of the aforesaid facts and the clear position of law as discussed above, I am convinced that the assessee had no reasonable

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 1936/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Jan 2026AY 2014-15

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Shri Ganesh Sudhakar Bare, CIT-

Section 271Section 271(1)(c)

Mahendra Singh Dharampal & Co., Udaipur vs. ACIT, Circle-2, Udaipur

In the result, the appeal of the assessee is allowed

ITA 229/JODH/2024[2011-12]Status: DisposedITAT Jodhpur28 Jan 2026AY 2011-12

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blemahendra Singh Dharampal & Acit Circle 2, Co Udaipur - 313001 15-18, Diamond Plazza, Hiran Magri Sect 5, Udaipur - 313001 Pan No. Aadfm 9764 A Assessee By Shri Yogesh Pokharna, C.A. (Physical) Revenue By Shri K.C. Meena, Addl. Cit-Dr (Virtual) Date Of Hearing 13.01.2026. Date Of Pronouncement 28.01.2026. Order Dr. Mitha Lal Meena, A.M.: The Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax, Appeal [Hereinafter Referred To As The Cit(A)] Udaipur Dated 19.03.2024 For The Assessment Year 2011-12 Challenging Therein Confirmation Of Penalty Of Rs. 1,54,500/- Levied U/S 271(1)(C) By The Ao.

Section 113Section 139(4)Section 144Section 153ASection 271(1)(c)Section 40

loss. However, after making disallowance remuneration of partners, the loss is reduced. Accordingly, he has held that it was a case of furnishing inaccurate particulars of loss in confirming the penalty. The Ld. Counsel for the assessee submitted that assesses has filed its original return of income ... revised computation of Income the total income is loss. However after making disallowance of remuneration of partners, the loss is further reduced. The furnishing inaccurate particulars include furnishing inaccurate particulars of loss. Thus, the claim of the appellant is found to be justified. 4. Thus, the penalty

Chartered Speed Limited, Ahmedabad vs. DCIT Circle 1(1)(1), Ahmedabad

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

ITA 2286/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2014-15

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 14ASection 271(1)(c)Section 36(1)(iii)

order, assessee filed an appeal before Ld. CIT(A) who has also confirmed the levy of penalty by holding that the assessee has furnished inaccurate particulars of income relating to the addition made u/s. 36(1)(iii) of the Act, thereby upheld the levy of penalty amounting to Rs.6 ... Rs.6,89,594/-. 6.3. Ld. Counsel for the assessee submitted that there was neither concealment of primary facts nor furnishing inaccurate particulars of income before the Income Tax Authorities. The assessee was in bona-fide belief that after purchase of body chassis and convert into bus is passive

Soni Somani Infrastructure, Pune vs. Assistant Commissioner of Income Tax Circle 1, Pune

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

ITA 2458/PUN/2025[2015-16]Status: DisposedITAT Pune28 Jan 2026AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2458/Pun/2025 िनधा"रण वष" / Assessment Year : 2015-16 Soni Somani Infrastructure, Vs. Acit, Circle-1, Solapur. 560/31, South Sadar Bazar, Vinayak Nagar, Solapur- 413003. Pan : Abvfs4209B Appellant Respondent Assessee By : Shri Shriniwas G. Bhutada Shri Vishnu D. Bhutada Revenue By : Smt. Sailee Dhole Date Of Hearing : 08.01.2026 Date Of Pronouncement : 28.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2015-16. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “Based On The Facts & In The Circumstances Of The Case, The Appellant Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(A) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The 'Act'), Against The Order Dated 27Th Aug 2025 (Hereinafter Referred To As The Impugned Order') Passed By The Commissioner Of Income Tax (Appeal)- Nfac

For Appellant: Shri Shriniwas G. BhutadaFor Respondent: Smt. Sailee Dhole

Section 143(3)Section 250Section 253(1)(a)Section 271(1)(c)

returned by the assessee at Rs.56,81,371/- and penalty proceedings u/s 271(1)(c) of the IT Act were also initiated for furnishing inaccurate particulars of income. In penalty proceedings, after considering the reply of the assessee, the Assessing Officer vide order dated 02.03.2020, levied penalty of Rs.34

Peda Subba Rao Unnam, Addanki vs. ITO, Ward-1, Ongole

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

ITA 1664/HYD/2025[2015-16]Status: DisposedITAT Hyderabad28 Jan 2026AY 2015-16

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 147Section 148Section 149Section 149(1)(a)Section 69A

Entire Proceedings. Objection: The Assessing Officer (AO) mechanically initiated penalty proceedings under Section 271(1)(c) in the assessment order itself, for both "furnishing inaccurate particulars of income" and "concealment of income." Crucially, these penalty proceedings were kept pending and not concluded, awaiting the outcome of the appeal. Argument: This

Ramesh Chowdhury, Kolkata vs. I.T.O., Ward - 31(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2123/KOL/2025[2015-2016]Status: DisposedITAT Kolkata28 Jan 2026AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Ramesh Chowdhury…………..……..………………….……….……….……Appellant 7, Padda Pukur Road, Kol – 700020. [Pan: Acspc5253B] Vs. Ito, Ward-31(4), Kolkata………...………………………......……...…..…..Respondent Appearances By: S. K. Kamaluddin, Ca, Appeared On Behalf Of The Appellant. Shri S B Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.07.2025 Of The National Faceless Appeal Centre (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Facts In Brief Are That The Assessee Is An Individual & Filed Its Original Return Of Income Declaring Income Of Rs. 8,68,870/- For The A.Y. 2015-16. Further The Case Of The Appellant Was Selected For The Scrutiny & The Notice U/S. 143(2) Was Issued. The Assessment Was Completed U/S 143(3) Of Act After Making The Disallowance On Account Of Sundry Creditors Bills Amounting To Rs.38,35,643/-. The Assessing Officer Also Initiated Penalty Proceedings U/S 271(1)(C) Of Act.

Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 274

particulars of your income’ wherein in the order of the Assessing Officer, the penalty proceedings u/s 271(1)(c) was initiated for ‘furnishing inaccurate particulars of income’. The ld. AR, therefore, stated that the Assessing Officer failed to mention any specific charge against the assessee for imposing the penalty ... above, we find that the Assessing Officer in his order while initiating the penalty proceedings u/s 271(1)(c) had mentioned that ‘furnishing inaccurate particulars of income’ and the notice u/s 274 r.w.s. 271 of the Act dated 29.12.2017, the Assessing Officer itself mentioned ‘have concealed the particulars of your

Stream Suppliers Pvt. Ltd., Kolkata vs. ITO, Ward 7(1), Kolkata

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

ITA 1936/KOL/2025[2016-2017]Status: DisposedITAT Kolkata28 Jan 2026AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144BSection 148Section 149(1)(b)Section 151ASection 250

against income under the other heads. Penalty proceedings under the provisions of the section 271(1)(c) of the Act for furnishing inaccurate particulars of its income of ₹1,49,38,316/- was initiated separately. Further, commission of ₹2,98,766/- was also added as unexplained expenditure of the assessee

Shree Krishna Woollen Mills Private Limited, Mumbai vs. DCIT, Mumbai

In the result, the appeal of the assessee is dismissed

ITA 6025/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Jan 2026AY 2012-13

Bench: Shri Sandeep Gosain & Shri Bijayananda Prusethshree Krishna Woollen Vs. Dcit Circle 15(3)(2), Aayakar Bhawan, Mills Pvt. Ltd. Mumbai-400020. Krishna Mills Compound, L. B.S. Marg, Bhandup West S.O, 400078, Mumbai. Pan/Gir No: Aabcs9353G (Appellant) (Respondent)

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

Court held that merely stating facts in a note or claiming an exemption does not absolve the assessee of the charge of furnishing inaccurate particulars, especially when the claim lacks legal merit and the particulars furnished are misleading. Further, the plea that the matter is sub-judice before ... justifies the imposition of penalty. In light of the above facts and settled legal principles, I find that the assessee has clearly furnished inaccurate particulars of income and concealed income to the tune of Rs. 4,88,19,661/-. The assessing officer was fully justified 5 ITA No.6025/MUM/2025/AY

Mr. Parasmal Jain, Chennai vs. ACIT, Central Circle-3(1), Chennai

In the result, Appeals filed by the assessee are allowed

ITA 3304/CHNY/2025[2013-14]Status: DisposedITAT Chennai27 Jan 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Respondent: Ms. Gouthami

failed to delete the inappropriate words in the notice relating to whether the notice is issued for concealment of income or for furnishing inaccurate particulars of income. He also referred to case laws citations. ITA No 3303-3304/Chny/2025 (AY 2012-13, 2013-24) MANI SRIDHAR

Mr. Parasmal Jain, Chennai vs. ACIT, Central Circle-3(1), Chennai

In the result, Appeals filed by the assessee are allowed

ITA 3303/CHNY/2025[2012-13]Status: DisposedITAT Chennai27 Jan 2026AY 2012-13

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Respondent: Ms. Gouthami

Alka Ashok Jagtap, Kalyan vs. Income Tax Officer, Kalyan

ITA 7524/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Jan 2026AY 2009-10

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokaralka Ashok Jagtap Income Tax Office C-304, Regency Avenue Rani Mansion Syndicate, Murbad Road, Vs. Kalyan, Kalyan Kalyan West, Thane- 421301, Kalyan Pan/Gir No. Ahtpj7760J (Applicant) (Respondent) Assessee By Shri Sunil Jain Revenue By Shri Surendra Mohan, Sr Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026

Section 143(1)Section 143(3)Section 147Section 148Section 154Section 271(1)(c)Section 274

without appreciating that the penalty was levied solely on account of the addition and not based on any independent finding of concealment or furnishing inaccurate particulars. 2. The entire assessment and penalty proceedings are vitiated as the AO failed to grant cross-examination of untested statement of Shri Mukesh Choksi

Khozema Bohra, Indore vs. Income Tax Officer, NFAC, Delhi

ITA 814/IND/2024[2013-14]Status: DisposedITAT Indore22 Jan 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 115BSection 147Section 250Section 253Section 271(1)(c)Section 68

section 115BBE of the Income Tax Act, 1961 at the rate of 30%. Penalty proceedings u/s. 271(1)(c) are initiated separately for furnishing inaccurate particulars of (Addition Rs.23,00,000/-income.” 2.2 That the Assessee being Aggrieved by the aforesaid “Impugned Assessment Order” prefers the first appeal u/s Page

Skyline Developers, Pune vs. The Income Tax Officer, Ward4(50, Pune

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

ITA 709/PUN/2023[2006-07]Status: DisposedITAT Pune20 Jan 2026AY 2006-07

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.709/Pun/2023 Assessment Year : 2006-07

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde

Section 143Section 143(3)Section 147Section 148Section 250Section 80I

disallowed and added to the total income of the assessee under the head Business Income. As the assessee has concealed this income by furnishing inaccurate particulars of income, penalty proceeding u/s 271(1)(c) of the Act is separately initiated.” 6. Aggrieved assessee preferred appeal before ld.CIT(A). During

Bmw Industries Limited, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

Appeals of the assessee are allowed

ITA 2587/KOL/2025[2016-2017]Status: DisposedITAT Kolkata20 Jan 2026AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsiyan &For Respondent: Shri Ms. Archana Gupta, DR

Section 143(3)Section 147Section 148Section 271(1)(c)Section 68

virtue of Explanation 4 to Section 271(1)(c) of the Act. Besides, we have noted that the assessee has not furnished inaccurate particulars of income as the sales were fully disclosed in the audited books of account, which was not in dispute and therefore in such scenario no penalty ... course of any proceedings under this Act, is satisfied that any person— (c )has concealed the particulars of his income or furnished inaccurate particulars of such income." A glance at this provision would suggest that in order to be covered, there has to be concealment of the particulars

Bmw Industries Limited, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

Appeals of the assessee are allowed

ITA 2586/KOL/2025[2015-2016]Status: DisposedITAT Kolkata20 Jan 2026AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsiyan &For Respondent: Shri Ms. Archana Gupta, DR

Section 143(3)Section 147Section 148Section 271(1)(c)Section 68

Bmw Industries Limited, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

Appeals of the assessee are allowed

ITA 2585/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsiyan &For Respondent: Shri Ms. Archana Gupta, DR

Section 143(3)Section 147Section 148Section 271(1)(c)Section 68

Dy. Commissioner of Income Tax, Mumbai vs. Kanakia Spaces Realty Private Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 6133/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Jan 2026AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2011-12 Dy. Commissioner Of Income Tax Kanakia Spaces Realty Room No. 420, Kautilya Bhawan, Private Limited Vs. G Block, Bandra Kurla Complex, Plot No. 8, Vilco Centre, 3Rd Mumbai- 400051 Floor, Subhash Road, Opp Garware House, Vile Parle East, Mumbai- 400057 Pan No. Aaccc 4199 F Appellant Respondent Assessee By : Ms. Shweta Vardhan : Shri. Hemanshu Joshi, Sr Dr Revenue By Date Of Hearing : 25/11/2025 : 20/01/2026 Date Of Pronouncement Order

For Appellant: Ms. Shweta Vardhan

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

also initiated penalty u/s 271(1)(c) of the Act in assessment order for furnishing inaccurate particulars of the Act in assessment order for furnishing inaccurate particulars of the Act in assessment order for furnishing inaccurate particulars of income. Aggrieved by the assessment order, the appellant filed appeal income. Aggrieved

The Punjab State Federation of Cooperative House Building Societies Ltd., Chandigarh vs. ACIT, Chandigarh

In the result, both the above appeals of the Assessee are dismissed

ITA 797/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh19 Jan 2026AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Atul Goyal, C.A (Virtual Mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 57oSection 80PSection 80P(2)(a)

reclassifying project income, the AO computed taxable income at Rs.91,14,190/- and initiated penalty proceedings u/s 271(1)(c) for concealment and furnishing inaccurate particulars. 5. Against the order of the AO the assessee went in appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the assessment

The Punjab State Federation of Cooperative House Building Societies Ltd., Chandigarh vs. DCIT, Chandigarh

In the result, both the above appeals of the Assessee are dismissed

ITA 1308/CHANDI/2016[2012-13]Status: DisposedITAT Chandigarh19 Jan 2026AY 2012-13

Bench: the appeal is finally heard.

For Appellant: Shri Atul Goyal, C.A (Virtual Mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 57oSection 80PSection 80P(2)(a)