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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

DCIT Central Circle Ajmer, Ajmer vs. Yashwant Kumar Sharma, Ajmer

In the result, the appeal of the revenue is dismissed and the cross

ITA 210/JPR/2023[2020-21]Status: DisposedITAT Jaipur19 Jul 2023AY 2020-21

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 210/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2020-21 DCIT, Central Circle, Ajmer cuke Vs. Yashwant Kumar Sharma F-108, Industrial Area, Makhupura Parbatpura, Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ASWPS 3791 E vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@C.O. No. 04/JP/2023 (Arising out of ITA Nos. 210/JP/2023) fu/kZkj.k o"kZ@Assessment Years : 2020-21 Yashwant Kumar Sharma

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. James Kurian (CIT) &
Section 139(1)Section 271ASection 274

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

Neel Controls, Mumbai vs. Commissioner of Income Tax (Appeals) National Faceless Appeal Centre, Mumbai

In the result, appeal filed by the Assessee stands allowed

ITA 1332/MUM/2023[2011-2012]Status: DisposedITAT Mumbai18 Jul 2023AY 2011-2012

Bench: Shri Prashant Maharishi, Am & Shri N. K. Choudhry, Jm

For Appellant: Sh. Parag Modi, Ld. CAFor Respondent: Sh. Ashok Kumar Ambastha, Ld
Section 133(6)Section 250Section 271Section 271(1)Section 271(1)(c)Section 274Section 69C

section 271(1)(c) of the Act on dated 20.03.2014 and ultimately vide penalty order dated 23.03.2018 held that the Assessee had furnished inaccurate particulars of income by debiting bogus purchases in his Profit & Loss A/c. This is clear case of furnishing inaccurate particulars of income. The AO consequently levied ... initiated penalty proceedings under section 271(1)(c) of the Act not only for concealment of income but also for furnishing inaccurate particulars of income and accordingly issued the notice dated 26-03-2015 under section 274 r.w.s. 271(1)(c) of the Act for concealment of income

Sheetal Mehra, New Delhi vs. ITO, Ward-40(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 907/DEL/2019[2010-11]Status: DisposedITAT Delhi17 Jul 2023AY 2010-11

Bench: Sh. Kul Bharat & Sh. Pradip Kumar Kediasheetal Mehra Vs. Ito Qp-40, 2Nd Floor, Ward – 40(1) Pitampura, New Delhi-34 New Delhi Pan No. Ajapm 1364 J (Appellant) (Respondent) Assessee By Shri Snehil, Adv. Revenue By Shri Anuj Garg, Sr. D.R. Date Of Hearing: 17.07.2023 Date Of Pronouncement: 17.07.2023

Section 271(1)(c)

penalty order passed by AO, it was noticed that the Assessing Officer has imposed penalty on a different premise i.e. furnishing inaccurate particulars of income. The CIT(A) in the first appeal confirmed the action of the AO on the grounds of ‘concealment of particulars of income’ de horse ... penalty imposed by AO alleging furnishing inaccurate particulars of income. 4. In this factual background, it is apparent that the basis and foundation for imposition of penalty has been altered by AO himself while imposing the penalty in departure to satisfaction formed in the course of assessment proceedings

Venkata Rama Satyanarayana Varma Vegesna, Visakhapatnam vs. DCIT/ACIT, Circle-3(1), Visakhapatnam

In the result, appeal filed by the assessee is allowed

ITA 165/VIZ/2022[2011-12]Status: DisposedITAT Visakhapatnam14 Jul 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.165/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2011-12) Venkata Rama Satyanarayana Varma Vs. National E-Assesment Centre, Vegesna Delhi 10-50-2, Lazarus Bangalow (Dcit/Acit Waltair Main Road Circle-3(1) Visakhapatnam Visakhapatnam) [Pan : Aagts9608E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shrin C.M.Ravi Prasad, Ar प्रत्यधथी की ओर से / Respondent By : Shri On Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 24.04.2023 घोर्णध की तधरीख/Date Of Pronouncement 14.07.2023 : आदेश /O R D E R Per Shri Duvvuru Rl Reddy: This Appeal Is Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No. Itba/Nfac/S/250/2022- 23/1043814974(1) Dated 12.07.2022, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) U/S 271(1)(C) Of The Income Tax Act, 1961 (In Short “Act”) Dated 14.02.2022 For The Assessment Year (A.Y.) 2011-12. 2

For Appellant: Shrin C.M.Ravi Prasad, ARFor Respondent: Shri ON Hari Prasada Rao, DR
Section 143(3)Section 2(22)(e)Section 271(1)(c)

made on account of deemed dividend u/s 2(22)(e). The AO also initiated penalty proceedings u/s 271(1)(c) for furnishing inaccurate particulars of income. Against the said order, the assessee filed an appeal before the Ld.CIT(A) and the Ld.CIT(A) partly allowed the appeal of the assessee ... compliance was made by the assessee. After due consideration of the facts of the case, the AO concluded that the assessee has furnished inaccurate particulars of income, leading to concealment of income and levied penalty u/s 271(1)(c) of Rs.6,18,000/- @100% of the tax sought

Shri Santosh Kumar Agarwala, Cuttack vs. ACIT, Circle- 2(1), Cuttack

In the result, appeal of the assessee stands allowed

ITA 190/CTK/2023[2009-10]Status: HeardITAT Cuttack13 Jul 2023AY 2009-10

Bench: Before Shri George Mathan, Judicialita Nos.189 & 190/Ctk/20 /Ctk/2023 Assessment Year : 2009-10 Santosh Kumar Santosh Kumar Agarwala, Vs. Acit, Circle Acit, Circle-2(1), Sector-6, Cda, Cuttack 6, Cda, Cuttack Cuttack Pan/Gir No. Pan/Gir No.Aaspa 3698Q (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Mohit Sheth Mohit Sheth, Ar Revenue By : Shri S.C.Mohanty, Sr , Sr. Dr Date Of Hearing : 13/07 7/2023 Date Of Pronouncement : 13/0 /07/2023 O R D E R

For Appellant: Shri Mohit ShethFor Respondent: Shri S.C.Mohanty, Sr
Section 148

appellant is ambiguous, as it is not clear whether the default of the assessee is concealment of particulars of income or furnishing inaccurate particulars of income. The proceedings by the AO is improper and illegal as notice being bad-in-law and charged against the assessee being ambiguous. The levy ... that the Assessing Officer has not categorically specified as to whether the penalty is being levied for concealment particulars of income or furnished inaccurate particulars of income. In view of the decision of Hon’ble Supreme Court in the case of Dillip N.Shroff vs JCIT(supra), the penalty as levied

Shri Santosh Kumar Agarwala, Cuttack vs. ACIT, Circle- 2(1), Cuttack

In the result, appeal of the assessee stands allowed

ITA 189/CTK/2023[2009-10]Status: HeardITAT Cuttack13 Jul 2023AY 2009-10

Bench: Before Shri George Mathan, Judicialita Nos.189 & 190/Ctk/20 /Ctk/2023 Assessment Year : 2009-10 Santosh Kumar Santosh Kumar Agarwala, Vs. Acit, Circle Acit, Circle-2(1), Sector-6, Cda, Cuttack 6, Cda, Cuttack Cuttack Pan/Gir No. Pan/Gir No.Aaspa 3698Q (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Mohit Sheth Mohit Sheth, Ar Revenue By : Shri S.C.Mohanty, Sr , Sr. Dr Date Of Hearing : 13/07 7/2023 Date Of Pronouncement : 13/0 /07/2023 O R D E R

For Appellant: Shri Mohit ShethFor Respondent: Shri S.C.Mohanty, Sr
Section 148

appellant is ambiguous, as it is not clear whether the default of the assessee is concealment of particulars of income or furnishing inaccurate particulars of income. The proceedings by the AO is improper and illegal as notice being bad-in-law and charged against the assessee being ambiguous. The levy ... that the Assessing Officer has not categorically specified as to whether the penalty is being levied for concealment particulars of income or furnished inaccurate particulars of income. In view of the decision of Hon’ble Supreme Court in the case of Dillip N.Shroff vs JCIT(supra), the penalty as levied

Deputy Commissioner of Income Tax, Circle - 1(1), Panaji vs. Shri Edgar Braz Afonso, Calangute

Appeals of the Revenue are DISMISSED

ITA 98/PAN/2019[2010-11]Status: DisposedITAT Panaji13 Jul 2023AY 2010-11

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle - 1(1), Panaji vs. Shri Edgar Braz Afonso, Calangute

Appeals of the Revenue are DISMISSED

ITA 97/PAN/2019[2009-10]Status: DisposedITAT Panaji13 Jul 2023AY 2009-10

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle -1(1), Panaji vs. Mrs Natalina Vaz., Caranzalem, Goa

Appeals of the Revenue are DISMISSED

ITA 112/PAN/2019[2010-11]Status: DisposedITAT Panaji13 Jul 2023AY 2010-11

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle -1(1), Panaji vs. Mrs Natalina Vaz., Caranzalem, Goa

Appeals of the Revenue are DISMISSED

ITA 111/PAN/2019[2009-10]Status: DisposedITAT Panaji13 Jul 2023AY 2009-10

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle - 1(1), Panaji vs. Peter Soccoro Vaz, Caranzalem, Goa

Appeals of the Revenue are DISMISSED

ITA 108/PAN/2019[2010-11]Status: DisposedITAT Panaji13 Jul 2023AY 2010-11

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle - 1(1), Panaji vs. Peter Soccoro Vaz, Caranzalem, Goa

Appeals of the Revenue are DISMISSED

ITA 107/PAN/2019[2009-10]Status: DisposedITAT Panaji13 Jul 2023AY 2009-10

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle -1(1), Panaji vs. Smt Vanda Afonso, Calangute

Appeals of the Revenue are DISMISSED

ITA 102/PAN/2019[2010-11]Status: DisposedITAT Panaji13 Jul 2023AY 2010-11

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Deputy Commissioner of Income Tax, Circle -1(1), Panaji vs. Smt Vanda Afonso, Calangute

Appeals of the Revenue are DISMISSED

ITA 101/PAN/2019[2009-10]Status: DisposedITAT Panaji13 Jul 2023AY 2009-10

Bench: Hon’Ble Shri S S Godara & Shri G. D. Padmahshali(Through Virtual Hearing) Sr

For Appellant: Shri Milind KulkarniFor Respondent: Shri Prabhakar Anand DJ
Section 139(1)Section 153CSection 2(22)(e)Section 250Section 271Section 271(1)(c)

Ld.CIT(A) erred in deleting the penalty levied by the Assessing Officer u/s. 271(l)(c) of the I.T. Act, for furnishing inaccurate particulars of income. 2. On facts and in circumstances of the case, the Ld. CIT(A) erred in not considering the decision of the Hon'ble ITAT

Jagani Vinodrai Gopaldas (HUF), Rajkot vs. The ITO, Ward-1 (2) (4), Rajkot

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

ITA 59/RJT/2023[2014-15]Status: HeardITAT Rajkot12 Jul 2023AY 2014-15

Bench: Shri Waseem Ahmed & Shri T.R Senthil Kumarआयकर अपील सं./Ita No. 59/Rjt/2023 िनधा"रण वष"/Asstt. Year: 2014-15 Jagani Vinodrai Gopaldas Huf, Income-Tax Officer, 62 – Suraj Appartment, Vs. Ward-1(2)(4), No.1 Shroff Road, Rajkot. Opp. Church, Nfac, Delhi Rajkot-360001. Pan: Aaahj9710N

For Appellant: Shri R.D Lalchandani, A.RFor Respondent: Shri K.L Solanki, Sr. D.R
Section 10(38)Section 271(1)(c)

imposed. 5.1 The Ld. AR also contended that the AO in the Assessment Order has initiated penalty proceedings on the charge of furnishing inaccurate particulars of income whereas the penalty has been imposed on account of concealment of income in the penalty order. Thus ... penalty was to be imposed u/s 271(1)(c) of the Act, the same can be under the charge of furnishing inaccurate particulars of income. 7.1 Moving further, we note that it is a trite law that every addition or disallowance made during the assessment proceedings cannot be treated either

Shri Vishwajit N. Mashru, Rajkot vs. The ITO-Ward-1 (2) (3), Rajkot

In the result, the appeal of the assessee is allowed in above terms

ITA 270/RJT/2019[2013-14]Status: DisposedITAT Rajkot11 Jul 2023AY 2013-14

Bench: Smt.Annapurna Gupta & Ms. Madhumita Roy

For Appellant: Shri Kalpesh Doshi, ARFor Respondent: Shri B.D. Gupta, Sr.DR
Section 271(1)(c)Section 68Section 69

added back to the total income. Penalty u/s.271(1)(c) of the IT Act, is initiated for furnishing inaccurate particulars of income and concealment of income. (Addition of Rs.34,77,658/-)” 4.1. The ld.counsel for the assessee contended that this peak balance was positive cash balance appearing in its cash

R P Wood Products Pvt Ltd, Naya Bazar Ajmer vs. DCIT Central Circle Ajmer, Jaipur Road Ajmer

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 302/JPR/2023[2018-19]Status: DisposedITAT Jaipur11 Jul 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Sh. Shailendra Sharma (CIT) a
Section 132Section 153ASection 271ASection 274

bonafide. In these circumstances, there appears to be no basis for imposition of penalty on the ground that the assessee furnished inaccurate particulars of income. Since the Revenue have not placed before us any material nor brought to our notice any contrary decision so as to enable us to take ... does not specify the charge against the assessee as to whether it is for concealing particulars of income or furnishing inaccurate particulars of income. The argument of the department that the provisions of section 292B of the 22 R. P. Wood Products Pvt. Ltd. vs. DCIT Act will cure

Dhanesh Trading Co., Mumbai vs. ITO-19 (1) (4), Mumbai

In the result, the four appeals filed by the assessee’s are allowed partly

ITA 1458/MUM/2021[2011-12]Status: DisposedITAT Mumbai10 Jul 2023AY 2011-12

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2008-09 Mr. Dhanesh Mulji Gala, Ito Wd 19(1)(4), 137, 1St Floor, Kika Street, Mumbai. Gulalwadi, Vs. Mumbai-400004. Pan No. Aaafp 1969 L Appellant Respondent

For Appellant: Mandar VaidyaFor Respondent: Ms. Indira Adakil, DR
Section 143(3)

total income of the assesse as profit earned from such purchases. Proceedings under 274 r.w. 271(1)(c) are separately initiated for furnishing inaccurate particulars of income, leading to concealment of income chargeable to tax.” 5. On further appeal, the Ld. CIT(A) upheld the validity of the reassessment proceedings

Dhanesh Trading Company, Mumbai vs. ITO -19(1) (4), Mumbai

In the result, the four appeals filed by the assessee’s are allowed partly

ITA 1457/MUM/2021[2010-11]Status: DisposedITAT Mumbai10 Jul 2023AY 2010-11

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2008-09 Mr. Dhanesh Mulji Gala, Ito Wd 19(1)(4), 137, 1St Floor, Kika Street, Mumbai. Gulalwadi, Vs. Mumbai-400004. Pan No. Aaafp 1969 L Appellant Respondent

For Appellant: Mandar VaidyaFor Respondent: Ms. Indira Adakil, DR
Section 143(3)

total income of the assesse as profit earned from such purchases. Proceedings under 274 r.w. 271(1)(c) are separately initiated for furnishing inaccurate particulars of income, leading to concealment of income chargeable to tax.” 5. On further appeal, the Ld. CIT(A) upheld the validity of the reassessment proceedings

Dhanesh Trading Co., Mumbai vs. ITO-19(1) (4), Mumbai

In the result, the four appeals filed by the assessee’s are allowed partly

ITA 1456/MUM/2021[2009-10]Status: DisposedITAT Mumbai10 Jul 2023AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2008-09 Mr. Dhanesh Mulji Gala, Ito Wd 19(1)(4), 137, 1St Floor, Kika Street, Mumbai. Gulalwadi, Vs. Mumbai-400004. Pan No. Aaafp 1969 L Appellant Respondent

For Appellant: Mandar VaidyaFor Respondent: Ms. Indira Adakil, DR
Section 143(3)

total income of the assesse as profit earned from such purchases. Proceedings under 274 r.w. 271(1)(c) are separately initiated for furnishing inaccurate particulars of income, leading to concealment of income chargeable to tax.” 5. On further appeal, the Ld. CIT(A) upheld the validity of the reassessment proceedings