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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

Shivnandan Prasad & Sons, Hapur vs. ITO Ward-2(3)(5), Hapur

In the result, the appeals of the assessee are allowed

ITA 853/DEL/2023[2013-14]Status: DisposedITAT Delhi02 Apr 2024AY 2013-14

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

For Appellant: Sh. Nitish Garg, CAFor Respondent: Sh. Javed Akhtar, CIT-DR
Section 143(3)Section 271(1)(c)

computed on estimated basis penalty under Section 271(1)(c) of the Act cannot be levied for concealment of income or for furnishing inaccurate particulars of income. 4. The ld. DR strongly supported the orders of the authorities below. 5. Heard rival submissions perused the orders of the authorities below

Namdeo Indarrao Gore, Pune vs. Dy. Commissioner of Income Tax, Circle 5 Pune, Pune

ITA 1397/PUN/2023[2015-16]Status: DisposedITAT Pune27 Mar 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1397/Pun/2023 िनधा"रण वष" / Assessment Year : 2015-16 Namdeo Indarrao Gore, The Dy.Commissioner Of Subhadra Cme Engineers, V Income Tax, Plot No.1, Subhadra House, S Circle-5, Pune. Nanded Phata, Maharashtra – 411041. Pan: Aavpg0671L Appellant / Assessee Respondent / Revenue Assessee By Shri Rohit S. Tapadiya – Ca Revenue By Shri Ramnath P Murkunde – Ar Date Of Hearing 27/03/2024 Date Of Pronouncement 27/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 26.10.2023. The Assessee For A.Y.2015-16 Has Raised The Following Grounds Of Appeal : “1. The Ld.Ao Erred In Making & Ld. Cit(A) Erred In Confirming An Addition Of Rs.30,71,906/- U/S 41(1) Of The Income Tax Act On Account Of Unpaid Sundry Creditors. Namdeo Indarrao Gore [A]

Section 250Section 271(1)(c)Section 41(1)

same is added back to the total income of the assessee. Penalty u/s 271(1)(c) is hereby initiated for furnishing inaccurate particulars of income.” 3. Aggrieved by the assessment order, the assessee filed appeal before the ld.CIT(A). Before ld.CIT(A), assessee failed to file any submission, though ld.CIT

Shri Popat Karbhari Bhalerao, Nashik vs. Income Tax Officer, Ward-2(1), Nashik

In the result, appeal of the assessee is allowed

ITA 1324/PUN/2023[2018-19]Status: DisposedITAT Pune26 Mar 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1323 & 1324/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 & 2018-19 Shri Popat Karbhari Bhalerao, The Income Tax Officer, Yeshdei Niwas, Maratha V Ward-2(1), Nashik. Nagar, Near Rajrajeshwari S Mangal Karyalay, Jailroad, Nashik Road, Nashik-422101. Pan: Aaqpb3523N Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A)[Nfac] For A.Y.2017-18 Dated 02.09.2022 Under Section 250 Of The Income Tax Act, 1961, Emanating From Penalty Order Under Section 270A Of The Act, Dated 30.12.2021. The Assessee Raised The Following Grounds Of Appeal :

Section 147Section 24Section 250Section 270ASection 270A(9)Section 270A(9)(e)Section 274Section 9

assessee submits that in the reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of ‘furnishing inaccurate particulars of income’ also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been

Shri Popat Karbhari Bhalerao, Nashik vs. Income Tax Officer, Ward.2(1), Pune

In the result, appeal of the assessee is allowed

ITA 1323/PUN/2023[2017-18]Status: DisposedITAT Pune26 Mar 2024AY 2017-18

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1323 & 1324/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 & 2018-19 Shri Popat Karbhari Bhalerao, The Income Tax Officer, Yeshdei Niwas, Maratha V Ward-2(1), Nashik. Nagar, Near Rajrajeshwari S Mangal Karyalay, Jailroad, Nashik Road, Nashik-422101. Pan: Aaqpb3523N Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A)[Nfac] For A.Y.2017-18 Dated 02.09.2022 Under Section 250 Of The Income Tax Act, 1961, Emanating From Penalty Order Under Section 270A Of The Act, Dated 30.12.2021. The Assessee Raised The Following Grounds Of Appeal :

Section 147Section 24Section 250Section 270ASection 270A(9)Section 270A(9)(e)Section 274Section 9

assessee submits that in the reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of ‘furnishing inaccurate particulars of income’ also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been

DCIT CC- 3(4), Mumbai vs. Bhawanishankar Harishchandra Sharma, Mumbai

ITA 2764/MUM/2023[2007-08]Status: DisposedITAT Mumbai26 Mar 2024AY 2007-08

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha
Section 132Section 143(3)Section 153ASection 271(1)(c)Section 4Section 50C(2)

Meanwhile, penalty proceedings were also initiated under Section 4. 271(1)(c) of the Act for furnishing inaccurate particulars of income. Vide order, dated 29/03/2018, the Assessing Officer levied penalty of INR 1,08,76,000/- under Section 271(1)(c) of the Act. However, in appeal preferred ... penalty, vide order, dated 29/03/2018, the CIT(A) deleted the penalty levied under Section 271(1)(c) of the Act for furnishing inaccurate particulars of income. The present appeal has been preferred by the Revenue against the aforesaid order of the CIT(A) on the grounds reproduced in paragraph

Sumangal Glass Pvt. Ltd., Kutch vs. The Dy.CIT, Circle-4(1)(1), Ahmedabad

In the result, the appeal filed by the assesee is hereby allowed

ITA 676/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad22 Mar 2024AY 2011-12

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita No. 676/Ahd/2023 धििाधरणवरध/Asstt. Year: 2011-2012 Sumangal Glass Pvt. Ltd., D.C.I.T, Plot No.617/1-618-620, Vs. Circle-4(1)(1), Nh-8A, Po. Samakhiyari (Piprapati), Ahmedabad Bhachau Taluka, Samakhiyari-370150. Pan: Aaics6992G

For Appellant: Shri Manish J Shah, ARFor Respondent: Shri Alpesh Parmar, Sr. DR
Section 271(1)(c)

levied by the AO at Rs. 13,83,130/- being 100% of tax amount sought to be evaded on account of furnishing inaccurate particulars of income. On appeal, the Ld. CIT(A) was also pleased to uphold the order of the AO. 4. Being aggrieved by the order ... claim of the assessee could not be regarded either as "false" or not "bonafide" so as to conclude that assessee has furnished inaccurate particulars of income. Therefore, we set aside the orders of the authorities below and allow the appeal of the assessee. 7.2 In view of the above

Sunil Chunilal Kumavat, Nashik vs. ITO Ward 2(1), Nashik

ITA 1447/PUN/2023[2016-17]Status: DisposedITAT Pune22 Mar 2024AY 2016-17

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta
Section 270ASection 270A(8)Section 271(1)(c)Section 80C

foremost assessment year 2016- 17 had concluded that the assessee’s bogus claim under sec.80C deduction(s) is an instance of “furnishing inaccurate particulars of income” in para-iii pages 7 to 8 in the NFAC’s order. Whereas it’s impugned discussion in para.7.9 onwards holds

Sunil Chunilal Kumavat, Nashik vs. ITO Ward 2(1), Nashik

ITA 1402/PUN/2023[2018-19]Status: DisposedITAT Pune22 Mar 2024AY 2018-19

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta
Section 270ASection 270A(8)Section 271(1)(c)Section 80C

foremost assessment year 2016- 17 had concluded that the assessee’s bogus claim under sec.80C deduction(s) is an instance of “furnishing inaccurate particulars of income” in para-iii pages 7 to 8 in the NFAC’s order. Whereas it’s impugned discussion in para.7.9 onwards holds

Sunil Chunilal Kumavat, Nashik vs. ITO Ward 2(1), Nashik

ITA 1401/PUN/2023[2017-18]Status: DisposedITAT Pune22 Mar 2024AY 2017-18

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta
Section 270ASection 270A(8)Section 271(1)(c)Section 80C

foremost assessment year 2016- 17 had concluded that the assessee’s bogus claim under sec.80C deduction(s) is an instance of “furnishing inaccurate particulars of income” in para-iii pages 7 to 8 in the NFAC’s order. Whereas it’s impugned discussion in para.7.9 onwards holds

Smt. Shobha Lakshman, Bengaluru vs. Income-Tax Officer, Ward-7(2)(4), Bengaluru

In the result the appeal filed by the Assessee is allowed

ITA 198/BANG/2024[2013-14]Status: DisposedITAT Bangalore22 Mar 2024AY 2013-14

Bench: Shri N. K. Choudhry, Jm & Shri Laxmi Prasad Sahu, Am

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Subramanian S., JCIT
Section 143(3)Section 250Section 274Section 54F

respectively on account of Long Term Capital Gain and un-explained investment. The AO also initiated the penalty proceedings for furnishing inaccurate particulars of income and consequently issued notice u/s. 274 r.w.s. 271(1)(c) of the Act and ultimately vide penalty order dated 28.6.2019 imposed the penalty for concealment ... hence, the Assessee do not deserve any leniency. However considering the peculiar facts and circumstances of this case, as the limb (for furnishing inaccurate particulars of income) under which the penalty proceedings were initiated, infact not culminated into levy of any penalty but infact the AO admittedly imposed the penalty

Dion Global Solutions Ltd., New Delhi vs. DCIT, Cikrcle-7(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 7789/DEL/2018[2007-08]Status: DisposedITAT Delhi22 Mar 2024AY 2007-08

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: NoneFor Respondent: Shri Vivek Kumar Upadhyay, Sr.DR
Section 271Section 271(1)(c)

been accounted for in the subsequent assessment year, i.e., AY 2008-09 where the services have been rendered. The AO has alleged furnishing inaccurate particulars of income while assessing such revenue received in advance. 9. In this backdrop, we are of the view that while the additions made on this

Mukesh Kumar Ranka, Indore, Madhya Pradesh vs. Assistant Commissioner of Income Tax, Central Circle, Ujjain, Madhya Pradesh

Appeals are allowed

ITA 98/IND/2024[2018-19]Status: HeardITAT Indore21 Mar 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 132Section 132(4)Section 153ASection 271ASection 274

distinguish ‘Undisclosed income’ from under-reported income, misreported income and income suppressed by the concealment of particulars of income or by furnishing inaccurate particulars of income. To this end, the ‘Explanation’ cites the various ways in which ‘Undisclosed income’ can be manifested viz. money, bullion, jewellery or other valuable articles ... farce. Notice issued to the assessee reproduced (supra), does not show whether penalty proceedings were initiated for concealment of income or for furnishing inaccurate particulars of income or for having undisclosed income within the meaning of Section 271AAB of the Act. Notice in our opinion was vague. Hon’ble Karnataka

Mukesh Kumar Ranka, Indore, Madhya Pradesh vs. Assistant Commissioner of Income Tax, Central Circle, Ujjain, Madhya Pradesh

Appeals are allowed

ITA 97/IND/2024[2017-18]Status: HeardITAT Indore21 Mar 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 132Section 132(4)Section 153ASection 271ASection 274

distinguish ‘Undisclosed income’ from under-reported income, misreported income and income suppressed by the concealment of particulars of income or by furnishing inaccurate particulars of income. To this end, the ‘Explanation’ cites the various ways in which ‘Undisclosed income’ can be manifested viz. money, bullion, jewellery or other valuable articles ... farce. Notice issued to the assessee reproduced (supra), does not show whether penalty proceedings were initiated for concealment of income or for furnishing inaccurate particulars of income or for having undisclosed income within the meaning of Section 271AAB of the Act. Notice in our opinion was vague. Hon’ble Karnataka

Anju Jain, Lr Shri Sushil Jain, Indore, Madhya Pradesh vs. Assistant Commissioner of Income Tax, Central Circle, Ujjain, Madhya Pradesh

Appeals are allowed

ITA 104/IND/2024[AY 2017-18]Status: HeardITAT Indore21 Mar 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 132Section 132(4)Section 153ASection 271ASection 274

distinguish ‘Undisclosed income’ from under-reported income, misreported income and income suppressed by the concealment of particulars of income or by furnishing inaccurate particulars of income. To this end, the ‘Explanation’ cites the various ways in which ‘Undisclosed income’ can be manifested viz. money, bullion, jewellery or other valuable articles ... farce. Notice issued to the assessee reproduced (supra), does not show whether penalty proceedings were initiated for concealment of income or for furnishing inaccurate particulars of income or for having undisclosed income within the meaning of Section 271AAB of the Act. Notice in our opinion was vague. Hon’ble Karnataka

Anju Jain, Lr Sushil Jain, Indore, Madhya Pradesh vs. Assistant Commissioner of Income Tax, Central Circle, Ujjain, Madhya Pradesh

Appeals are allowed

ITA 103/IND/2024[AY 2018-19]Status: HeardITAT Indore21 Mar 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 132Section 132(4)Section 153ASection 271ASection 274

distinguish ‘Undisclosed income’ from under-reported income, misreported income and income suppressed by the concealment of particulars of income or by furnishing inaccurate particulars of income. To this end, the ‘Explanation’ cites the various ways in which ‘Undisclosed income’ can be manifested viz. money, bullion, jewellery or other valuable articles ... farce. Notice issued to the assessee reproduced (supra), does not show whether penalty proceedings were initiated for concealment of income or for furnishing inaccurate particulars of income or for having undisclosed income within the meaning of Section 271AAB of the Act. Notice in our opinion was vague. Hon’ble Karnataka

Jatin Enterprises, Mumbai vs. ACIT-19(2), Mumbai

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

ITA 3885/MUM/2023[2009-10]Status: DisposedITAT Mumbai21 Mar 2024AY 2009-10

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.3885/मुं/2023 (िन.व. 2009-10) Jatin Enterprises, 31, Savita Sadan, 1St Parsiwada, V.P.Road, C.P.Tank, Mumbai – 400 004. Pan: Aaafj-4667-N ...... अपीलाथ"/Appellant बनाम Vs. Acit-19(2),Mumbai, Matru Mandir, Income Tax Office,Tardeo, Mumbai – 400 007. ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Rajesh Bhende "ितवादी "ारा/Respondent By : Ms. Rajeshwari Menon, Sr.A.R सुनवाई की ितिथ/ Date Of Hearing : 20/03/2024 घोषणा की ितिथ/ Date Of Pronouncement : 21/03/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 01/09/2023, For The Assessment Year 2009-10, Confirming Levy Of Penalty U/S. 271(1)(C) Of The Income Tax Act, 1961[ In Short ‘The Act’].

For Appellant: Shri Rajesh BhendeFor Respondent: Ms. Rajeshwari Menon, Sr.A.R
Section 2Section 271Section 271(1)(c)Section 274Section 3

vitiate the penalty proceedings. In the present case, we find that in assessment order the Assessing Officer had initiated penalty proceedings for furnishing inaccurate particulars of income only. Since, both limbs i.e. “concealed particulars of income and furnished inaccurate particulars of income” are recorded in the notice, the notice

Abhishek Tejraj Doshi, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2944/MUM/2023[2013-14]Status: DisposedITAT Mumbai20 Mar 2024AY 2013-14

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleabhishek Tejraj Doshi V. Income Tax Officer 259, 2Nd Floor, Johari Mansion Jurisdiction Circle 19(1), Kalbadevi Road, Kalbadevi Mumbai, Mumbai Mumbai 400002 Pan: Aegpd9279J (Appellant) (Respondent) Shri Anil Sathe Assessee Represented By : Department Represented By : Shri Manoj Kumar Sinha

Section 10(38)Section 131Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 68

assessee u/s 68 of Page No. 8 Abhishek Tejraj Doshi the Act. Penalty proceeding u/ s 271 is initiated for furnishing inaccurate particulars of income with a view to concealment of income, 16. Further, an amount of Rs. 5,94,525/- i.e. 2% of Rs.2,97,26,257/- (commission paid ... assessee u/s. 69C of IT Act, 1961 on account of unexplained expenditure. Penalty proceeding u/s 271(1)(c) is initiated for furnishing inaccurate particulars of income with a view to concealment of income.” 7. Aggrieved, assessee preferred an appeal before the Ld. CIT(A) and filed detailed submissions. After considering

Income Tax Officer Ward-26(2)(1), Mumbai vs. Saraswati Wire and Cable Industries, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2548/MUM/2023[2011-12]Status: DisposedITAT Mumbai20 Mar 2024AY 2011-12

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar Singh
Section 143(3)Section 250Section 271(1)(c)

purchases. Thereafter, the Assessing Officer has levied penalty of Rs.8,13,793/- under section 271(1)(c) of the Act for furnishing inaccurate particulars of income. The assessee filed appeal before the Ld.CIT(A) against levying penalty. However, the Ld.CIT(A) has dismissed the appeal the appeals of the assessee

Mrs. Devyani Ajit Mulik, Nagpur vs. Assistant Commissioner of Income Tax, Circel-1, Nagpur

In the result, the appeal of the assessee is allowed

ITA 1/NAG/2023[2016-17]Status: DisposedITAT Nagpur18 Mar 2024AY 2016-17

Bench: Shri S.S.Godara & Dr. Dipak P. Ripote

Section 250Section 271(1)(c)Section 50C

assessee in the return of income and as calculated by the AO. AO also initiated penalty u/s.271(1)(c) for furnishing inaccurate particulars of income. Vide order dated 28.06.2019, AO levied penalty u/s. 271(1)(c) after considering the reply of the assessee for furnishing inaccurate particulars. Aggrieved

Datta Narayanrao Chapke, Purna vs. ACIT, Circle Jalna, Jalna

Appeal is allowed in above terms

ITA 1452/PUN/2023[2016-17]Status: DisposedITAT Pune12 Mar 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri G D Padmahshali

For Appellant: -None-For Respondent: Shri Ramnath P Murkunde
Section 271(1)(c)

without specifying correct charge for levy of penalty, as per Assessment order and notice of penalty, it is initiated for furnishing inaccurate particulars of income and in the final penalty order same is levied for concealment of income in penalty order. 2. On the facts and in the circumstances