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“furnishing inaccurate particulars of income”

PenaltySection 271(1)(c)Section 271(1)(c)1,616 judgments

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

Leading authorities on furnishing inaccurate particulars of income

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing furnishing inaccurate particulars of income

Intervalve Poonawalla Pvt. Ltd., Pune vs. DCIT, Central Circle 1(1), Pune

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

ITA 636/PUN/2025[2013-14]Status: DisposedITAT Pune27 May 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Intervalve Poonawalla Pvt. Ltd. Dcit, Central Circle 1(1), Fin Div. 16/B-1, Sarosh Bhavan, Pune Vs. 2Nd Floor, Dr. Ambedkar Road, Opp. Niv, Pune – 411001 Pan: Aaaci3917P (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Vishnu Bhutada Department By : Shri Ramnath P Murkunde Date Of Hearing : 14-05-2025 Date Of Pronouncement : 27-05-2025 O R D E R

For Appellant: Shri Nikhil S Pathak &For Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 143(3)Section 14ASection 263Section 271(1)(c)

wherein, it was held that a claim which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars of income by the assessee. We find force in the argument of the assessee on this count and, accordingly, we direct the Assessing Officer to delete the penalty

Trustar Diamond, Bandra East vs. Ward 19(3)(5), Mumbai

In the result, the appeal is accordingly allowed in the

ITA 1542/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 May 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhan

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

order u/s 143(3) of the Act determining the total income of Rs.18,60,620/-. Further the penalty proceedings were initiated for furnishing inaccurate particulars of income leading to concealment of income chargeable to tax and levied penalty of Rs. 3,74,900/- i.e. 100% of tax sought ... assessee has not been able to show the genuineness of the purchases and hence he has to be held responsible for furnishing inaccurate particulars of income and as such penalty imposed is justified. 8. What is concealment of income or inaccurate particulars of such income as contemplated by Section

Ruban Patliputra Hospital Private Limited, Patna vs. CIT, Patna

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

ITA 653/PAT/2024[2014-15]Status: DisposedITAT Patna26 May 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 653/Pat/2024 Assessment Year: 2014-2015 Ruban Patliputra Hospital Private Limited,……………………………………….………Appellant 19, Patliputra Colony, Patna-800013, Bihar [Pan:Aafcr2222R] -Vs.- Nfac,…………………………………………….…...Respondent New Delhi, Appearances By: Shri A.K. Rastogi, Sr. Advocate, Appeared On Behalf Of The Assessee Sm. Rinku Singh, Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 16, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 143(2)Section 148Section 271(1)(c)Section 35A

Rs.4,27,53,259/- as unexplained and initiated penalty proceedings under section 271(1)(c) of the Income Tax Act for furnishing inaccurate particulars of income. On being aggrieved, the assessee preferred an appeal before the ld. CIT(Appeals). 5. The ld. CIT(Appeals) has given several opportunities

Dudhsagar Research and Development Association, Mehsana vs. The DCIT(E) Circle-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1048/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad26 May 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & Shri ParinFor Respondent: Shri V Nandakumar, CIT DR
Section 271(1)(c)

regarding corpus donation. 3. Ld. NFAC ought to have considered fact that non acceptance of bona fide claim does not lead to furnishing inaccurate particulars of income which leads to penalty. Dudhsagar Research and Development Association vs. DCIT(E) Asst.Year –2014-15 - 2– 4. The order passed by lower authorities ... this issue against the assessee in quantum proceedings. However, this is by itself should not lead to automatic levy of penalty for furnishing inaccurate particulars of income when the full details with regards to these receipts as “corpus donation” have been submitted by the assessee during the course of assessment

Diesh Kumar Goyal, Kota vs. ITO, Ward-1(1), Kota

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

ITA 32/JPR/2025[2010-11]Status: DisposedITAT Jaipur22 May 2025AY 2010-11
For Appellant: Sh. Rajendra Sisodia, Adv
Section 143(3)Section 271(1)(c)Section 274Section 68Section 69

confirming the penalty order passed by the AO, notwithstanding the fact that the SCN u/s 274 r.w.s.271(1)(c) was issued for furnishing inaccurate particulars of income, where as penalty was levied for concealment of particulars of income. 3. The Ld. CIT(A) erred in confirming the penalty order passed ... erred in confirming the penalty order passed by the AO, notwithstanding the fact that the SCN_u/s_274 r.w.s.271(1)(c) was issuedfor furnishing inaccurate particulars of income, where as penalty was leviedfor concealment of particulars of income. 2.1 At the time of passing the assessment order, the AO after discussing

Ram Rama Products Pvc Pvt Ltd, Mumbai vs. ITO Ward 13(3)(1), Mumbai

Appeal of the assessee is allowed for statistical purposes

ITA 65/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 May 2025AY 2016-17

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vijay Kumar Biyani, ARFor Respondent: Shri Mukesh Thakwani, Sr. DR
Section 250Section 271(1)Section 37

interest expenses claimed of Rs.39.92.721/- is added to the total income of the assessee. Penalty proceedings u/s.271(1) are initiated separately for furnishing inaccurate particulars of income.” 3. The CIT(A) on further appeal confirmed the disallowance made by the AO. The assessee is in appeal before the Tribunal against

Sarath Manari Gopinathan, Mumbai vs. A O 34(3)(1), Mumbai

In the result, Assessee’s appeal is allowed, in the above terms

ITA 1090/MUM/2025[2015-2016]Status: DisposedITAT Mumbai22 May 2025AY 2015-2016

Bench: Shri Narender Kumar Choudhryassessment Year: 2015-16

For Appellant: Dinkle Hariya /Sruti KalyanikarFor Respondent: Shri Manoj Kumar Sinha, Sr. AR
Section 139(1)Section 250Section 271(1)(c)

taxed in the hands of the assessee as short term capital gain. Penalty proceedings u/s 271(1)(c) is being initiated for furnishing inaccurate particulars of income." In this regard, we would like to respectfully bring it to the notice of the learned Commissioner (Appeals) that the said Short Term

Vinod Omprakash Kainya, Mumbai vs. Assistant Commissioner of Income Tax, Circle 25(1), Mumbai

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

ITA 6429/MUM/2024[2009-2010]Status: DisposedITAT Mumbai20 May 2025AY 2009-2010

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2009-10 Vinod Omprakash Kainya, Asst. Cit Circle-25(1), Flat No. 41/42, Minal Apartment, Room No. 402, 4Th Floor, C-10, Juhu Tara Road, Santacruz West, Vs. Pratyaksh Kar Bhavan, Bkc, Mumbai-400054. Bandra East, Mumbai-400051. Pan No. Aglpk 1448 D Appellant Respondent

For Appellant: Mr. Sachin SarawagiFor Respondent: Ms. Kavita P. Kaushik, Sr. DR
Section 133(6)Section 143(1)Section 148Section 234ASection 271

accordingly, disallowed and added back to the total income of the assessee. Penalty proceedings u/s 271(1)(c) are separately initiated fro furnishing inaccurate particulars of income and for concealing the income.” 4. On further appeal, the Ld. CIT(A) upheld the finding of the Assessing Officer observing as under

Ramesh Kumar, Karnal vs. Income Tax Officer, Karnal

Appeal of the assessee is allowed

ITA 1279/DEL/2025[2012-13]Status: DisposedITAT Delhi20 May 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.1279/िद"ी/2025(िन.व. 2012-13) Ramesh Kumar, House No.2027, Opposite Civil Hospital, Nissing, Karnal, Haryana 132024 ...... अपीलाथ"/Appellant Pan: Azopk-6953-F बनाम Vs. Income Tax Officer, Aayakar Bhawan, 2Nd Floor, Sector 12, ..... "ितवादी/Respondent Karnal, Haryana 132001 अपीलाथ" "ारा/ Appellant By : Shri R R Singla, Chartered Accountant "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 20/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 20/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against An Ex-Parte Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 04.01.2025, For Assessment Year 2012-13. 2. Shri R R Singla, Appearing On Behalf Of The Assessee Submits That In Assessment Proceedings U/S. 144/147 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) Addition Was Made On Account Of Unexplained Cash Deposits Of Rs.28,50,000/- In Punjab National Bank, Karnal. The Assessee Failed To Respond To The Notices U/S. 148 Of The Act As Parallel Proceedings U/S. 148 R.W.S.

For Appellant: Shri R R Singla, Chartered AccountantFor Respondent: Shri Manoj Kumar, Sr. DR
Section 144Section 148Section 271(1)(c)Section 274Section 69A

penalty u/s. 271(1)(c) of the Act was levied by the AO vide order dated 02.02.2022 on the ground of furnishing inaccurate particulars of income. The penalty was initiated on one limb of section 271(1)(c) of the Act, whereas, it was levied on another limb of section ... penalty vide order dated 02.02.2022, the AO in penultimate paragraph of the order observed, "I am satisfied that the assessee has willfully furnished inaccurate particulars of income and thus concealed the particulars of his income". The manner in which the penalty has been levied clearly indicates ambiguity in the mind

Shashi Jivanlal Patel, Ahmedabad vs. The ITO, Ward-1(2)(2), Vadodara

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

ITA 1969/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad19 May 2025AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 147Section 148Section 271(1)(c)

levy of penalty u/s.271(1)(c) of Rs.9.27,896, on the ground that the appellant has furnished inaccurate particulars of income to the extent of Rs.36,06,319/-, without considering the submissions of the appellant. The levy of penalty u/s.271(1)(c) of Rs.9,27,896/-being ... ignoring the facts that the Ld. A.O. has levied the penalty of Rs.9,27,896/-, considering that the appellant has furnished inaccurate particulars of income to the extent of Rs.36,06,319/-as against total income restricted to NIL by Ld. CIT(A) as per order dated 29.03.2016. 3. Your

Deputy Commissioner of Income, Circle-1(3)(1), Mumbai vs. Vikas Deep Sales Private Limited, Mumbai

In the result, appeal of the revenue is dismissed

ITA 5869/MUM/2024[2012-13]Status: DisposedITAT Mumbai19 May 2025AY 2012-13

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

Section 133(6)Section 142(1)Section 143(3)Section 68

Penalty proceedings u/s 271(1)(c) read with Explanation 1 thereto are also initiated on this issue for furnishing inaccurate particulars of income.” 5. Ld. CIT(A) after noting down the identity, genuineness and creditworthiness of the lender companies, noted the following facts: - “i) Makeshworth Projects & Developers Ltd., Rs.2500

Smt. Rajeshwari Devi, Uttar Pradesh vs. Income Tax Officer, Shamli

In the result, impugned order is quashed and appeal of the assessee is allowed

ITA 1221/DEL/2025[2010-11]Status: DisposedITAT Delhi19 May 2025AY 2010-11

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: Shri Gaurav SachdevaFor Respondent: Shri Manoj Kumar, Sr. DR
Section 148Section 271(1)Section 271(1)(c)Section 50C

made by AO invoking deeming section, penalty u/s. 271(1)(c) of the Act cannot be levied for concealment of income or furnishing inaccurate particulars of income. In support of his submissions, the ld. AR placed reliance on following decisions:- “(i) CIT vs. Fortune Hotels and Estates ... satisfaction was recorded by the AO in the assessment order for initiating penalty proceedings for furnishing inaccurate particulars of income, whereas, while passing penalty order u/s. 271(1)(c) of the Act, the AO levied penalty for concealment of income. Penalty was initiated on one limb and finally levied

Venkateshwar Reddy Atigadda, Hyderabad vs. ACIT., Circle-8(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2013-14 and 2016-17 are allowed

ITA 1286/HYD/2024[2016-2017]Status: DisposedITAT Hyderabad16 May 2025AY 2016-2017

Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri Srinath Sadanala, DR
Section 139Section 147Section 148Section 271(1)(c)

Income Tax Act, 1961. 2. The Ld.CIT(A)-10, Hyderabad fail to note that the Appellant had not furnished inaccurate particulars of income and therefore the levy of penalty is unsustainable and must be cancelled. 3. Without prejudice to any of the aforesaid grounds a mere incorrect claim made ... well as the Ld.CIT(A) in respect of the investment made in the land cannot be held as furnishing inaccurate particulars of income or concealment of particulars of income, attracting penal provision u/s 271(1)(c) of the Act. In support of his contentions, he has relied upon the judgement

Venkateshwar Reddy Attigada, Hyderabad vs. ACIT., Circle-8(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2013-14 and 2016-17 are allowed

ITA 1285/HYD/2024[2013-2014]Status: DisposedITAT Hyderabad16 May 2025AY 2013-2014

Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)

For Appellant: Shri K.C.Devdas, ARFor Respondent: Shri Srinath Sadanala, DR
Section 139Section 147Section 148Section 271(1)(c)

Income Tax Act, 1961. 2. The Ld.CIT(A)-10, Hyderabad fail to note that the Appellant had not furnished inaccurate particulars of income and therefore the levy of penalty is unsustainable and must be cancelled. 3. Without prejudice to any of the aforesaid grounds a mere incorrect claim made ... well as the Ld.CIT(A) in respect of the investment made in the land cannot be held as furnishing inaccurate particulars of income or concealment of particulars of income, attracting penal provision u/s 271(1)(c) of the Act. In support of his contentions, he has relied upon the judgement

ACIT-23(1), Mumbai, Piramal Chamber vs. Chetan Pravin Chitalia, Mumbai

In the result, appeal of the revenue is dismissed

ITA 2100/MUM/2025[2009]Status: DisposedITAT Mumbai16 May 2025

Bench: Shri Saktijit Dey, Vice- & Shri Bijayananda Pruseth

Section 271(1)(c)Section 690

Rs.1,01,43,657/- from the above two parties. He also initiated penalty proceedings u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income and thereby concealing particulars of income. The penalty proceedings were kept in abeyance as the assessee has filed appeal against the assessment order ... submitted that the case of revenue right from the beginning is that the assessee has shown bogus purchases and thus, furnished inaccurate particulars of income. The stand of revenue is upheld by the ITAT in restricting the addition to the extent of 12.5%. Therefore, the penalty

Bright Enterprises Private Limited Mbd House, Gulab Bhawan Bahadur Shah Zafar Marg New Delhi, New Delhi vs. Assistant Commissioner of Income Tax Circle 5(1) New Delhi, Jao DCIT 4(2), New Delhi

In the result, the appeal of the Assessee is allowed

ITA 4792/DEL/2024[2010-2011]Status: DisposedITAT Delhi16 May 2025AY 2010-2011

Bench: Shri Mahavir Singh & Shri Manish Agarwalbright Enterprises Private Acit, Limited, Circle-5(1), Mbd House, Gulab Vs. New Delhi. Bhawan, Bahadur Shah Zagar Marg, Jao Dcit, 4(2), New Delhi-110002 New Delhi.

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

appeals, the levy of penalty u/s 271(1) (c) is unjustified, since no specific charge, either for concealment of income or for furnishing inaccurate particulars of income have been made while passing the order u/s 143(3) dated 28.03.2013 and, as such, on the basis of binding judgments of Apex ... leviable, since there is no specific charge, either for concealment of income or for furnishing inaccurate particulars of income have been made while passing the assessment order passed u/s. 143(3) of the Act dated 28.3.2013, hence, on the anvil of settled law on this issue, as referred above

ACIT-5(1)(1), Mumbai vs. Crystal Impex Limited, Mumbai

In the result, the appeal of revenue is partly allowed

ITA 985/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 May 2025AY 2015-16

Bench: Shri Saktijit Dey, Vice- & Shri Bijayananda Prusethआयकर अपील सं./Ita No.985/Mum/2025 Assessment Year: (2015-16) (Physical Hearing) Acit, Vs. Crystal Impex Ltd., Circle – 5(1)(1), Gr. Floor, My Home Apartment, Mumbai V. N. Malik X Laten, Forjeet, Gawalia Tank, Mumbai - 400036 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaac1264F (Appellant) (Respondent) Appellant By Shri Rajendra Joshi, Sr. Dr Respondent By Shri Ketal Vajani, Ar Date Of Hearing 13/05/2025 Date Of Pronouncement 15/05/2025

Section 143(1)Section 143(2)Section 148Section 14ASection 250Section 271(1)(c)Section 37Section 68

Unit (I&CI) and added Rs.3,32,48,807/-. He has separately initiated penalty u/s 271(1)(c) of the Act for furnishing inaccurate particulars of income. ITA No.985/MUM/2025/AY.2015-16 Crystal Impex Limited 3.1 The AO also disallowed Rs.34,612/- u/s 14A read with Rule 8D of the Income-tax Rules

Moraj Building Concepts Private Limited, Navi Mumbai vs. Income Tax Officer, Central Circle 5(2), Mumbai

The appeals are dismissed as having been rendered infructuous

ITA 302/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 May 2025AY 2016-17

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: NoneFor Respondent: Shri R. R. Makwana
Section 143(3)Section 153ASection 250Section 271(1)(c)

once again by not identifying one of the two offences and instead levy penalty for allegedly concealing the particulars of income by furnishing inaccurate particulars of income, xviii. in initiating penalty proceedings without recording his satisfaction in the assessment order or in notice that the facts recorded in assessment satisfied ... satisfied, in the course of any proceedings under the Act, that an Assessee has (a) concealed particulars of income; or (b) furnished inaccurate particulars of income. 11. On perusal of the Assessment Order, dated 26/12/2018, for the Assessment Year 2014-2015 we find that while making the addition of INR.1

Moraj Building Concepts Private Limited, Navi Mumbai vs. Income Tax Officer, Central Circle 5(2), Mumbai

The appeals are dismissed as having been rendered infructuous

ITA 279/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 May 2025AY 2015-16

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: NoneFor Respondent: Shri R. R. Makwana
Section 143(3)Section 153ASection 250Section 271(1)(c)

once again by not identifying one of the two offences and instead levy penalty for allegedly concealing the particulars of income by furnishing inaccurate particulars of income, xviii. in initiating penalty proceedings without recording his satisfaction in the assessment order or in notice that the facts recorded in assessment satisfied ... satisfied, in the course of any proceedings under the Act, that an Assessee has (a) concealed particulars of income; or (b) furnished inaccurate particulars of income. 11. On perusal of the Assessment Order, dated 26/12/2018, for the Assessment Year 2014-2015 we find that while making the addition of INR.1

Moraj Building Concepts Private Limited, Navi Mumbai vs. Income Tax Officer Central Circle 5(2), Mumbai

The appeals are dismissed as having been rendered infructuous

ITA 278/MUM/2025[2014-15]Status: DisposedITAT Mumbai15 May 2025AY 2014-15

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SMT RENU JAUHRI (Accountant Member)

For Appellant: NoneFor Respondent: Shri R. R. Makwana
Section 143(3)Section 153ASection 250Section 271(1)(c)

once again by not identifying one of the two offences and instead levy penalty for allegedly concealing the particulars of income by furnishing inaccurate particulars of income, xviii. in initiating penalty proceedings without recording his satisfaction in the assessment order or in notice that the facts recorded in assessment satisfied ... satisfied, in the course of any proceedings under the Act, that an Assessee has (a) concealed particulars of income; or (b) furnished inaccurate particulars of income. 11. On perusal of the Assessment Order, dated 26/12/2018, for the Assessment Year 2014-2015 we find that while making the addition of INR.1