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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 42 1 1 Mumbai, Mumbai vs. Devleela Developers, Mumbai

In the result present appeal of the assessee stands allowed

ITA 2097/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Oct 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawaldcit – 42(1)(1) Vs. Devleela Developers Room No. 732, Kautilya 604-605, Aravalli Bhavan Bkc (E), Mumbai – Business Centre, 400051. Ramdas Sutrale Marg, Borivali (W) Pan/Gir No. Aacfd5181B (Applicant) (Respondent)

Section 142(1)Section 250

added to the total income of the assessee. Penalty proceedings u/s.271(1)(c) of the Act is initiated separately for furnishing inaccurate particulars of income." 5 Devleela Developers, Mumbai. And further submitted that the order passed by the Ld. CIT(A) is against the facts placed on record therefore Requested

Deputy Commissioner of Income Tax, Thiruvananthapuram vs. Rajakumari Shopping Amall LLP, Attingal

In the result, the appeal of the revenue is dismissed

ITA 597/COCH/2025[2016-17]Status: DisposedITAT Cochin29 Oct 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Dcit, Central Circle .......... Appellant Aayakar Bhavan, Kawdiar, Thiruvananthapuram Vs. Rajkumari Shopping Mall Llp ......... Respondent Amc 11/556, City Plaza, Nh Road Attingal 695101 [Pan: Aaqfr1222B] Assessee By: Shri V.M. Veeramani, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Shri V.M. Veeramani, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 144Section 250Section 271(1)(c)Section 274Section 68

specifically mentioned whether the penalty is proposed in respect of concealment of income or for furnishing inaccurate particulars of income. The appellant contended that in the absence of specific and particular mentioning of the reason for the penalty, the penalty notice itself is invalid and as a result the imposition ... Assessing Officer failed to specify the particular limb—whether the penalty proceedings were initiated for “concealment of income” or for “furnishing inaccurate particulars of income.” It is well-settled by the Hon’ble High Court of Kerala inPCIT vs. Ambadi Krishna Menon (163 taxmann.com 141) (Ker) as well

Rupesh Tambi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

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

ITA 1470/JPR/2024[2015-16]Status: DisposedITAT Jaipur29 Oct 2025AY 2015-16
For Appellant: Shri S. R. Sharma, CA &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 1Section 132Section 133ASection 153ASection 271Section 271A

whereas in the context of section 271AAB of the Act even these are not required to be proved whether the assessee furnished inaccurate particulars of income or concealed the particulars of income. The approach of the section 271AAB of the Act is completely different and there is no such onus ... after referring to the decision of Hon'ble Supreme Court in the case of T. Ashok Pai (Supra) held as under:- Concealment, furnishing inaccurate particulars of income are different. Thus the Assessing officer while issuing notice has to come to the conclusion that whether is it a case of concealment

Saradambika Power Plant (P) Ltd, Srikakulam vs. The Asst. Commissioner of Income Tax, Circle-3(1), Visakhapatnam

In the result, the appeal by the assessee is allowed

ITA 281/VIZ/2025[2010-11]Status: DisposedITAT Visakhapatnam27 Oct 2025AY 2010-11

Bench: Shri Balakrishnan Sshri Sandeep Singh Karhailsaradambika Power Plant (P) Ltd., Plot No.15, Konna Street, Radha Krishna Nagar Colony, Srikakulam. Andhra Pradesh - 532001 ............... Appellant Pan: Aajcs5970R V/S Assistant Commissioner Of Income Tax, Circle – 3(1), ……………… Respondent Visakhapatnam

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr.DR
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 3Section 40A(3)Section 43B

submitted that the AO has not specified whether the penalty has been levied for concealment of income or furnishing inaccurate particulars of income. 6. On the other hand, the learned Departmental Representative vehemently relied upon the order passed by the lower authorities. 7. We have considered the submissions of both

Nidhiben Mrugeshkumar Shah, Anand vs. The ACIT, (OSD), Ward-5, Anand

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

ITA 1627/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2011-12

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1627/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2011-12) बनाम/ Nidhiben Mrugeshkumar Assistant Commissioner Shah Of Income Tax (Osd) Vs. 3, Laksh Gold Bunglows, Ward-5, Anand B/H. Dz Patel High School, 80 Feet Road, Vidyanagar Road, Anand – 388001, Gujarat "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aprpj4087Q (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Viranch Modi, Ar ""यथ" क" ओर से/Respondent By : Smt. Kakoli Uttam Ghosh, Sr. Dr Date Of Hearing 13/10/2025 17/10/2025 Date Of Pronouncement

For Appellant: Shri Viranch Modi, ARFor Respondent: Smt. Kakoli Uttam Ghosh, Sr. DR
Section 271(1)(c)

National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi dated 18.06.2025 confirming the levy of penalty for concealing particulars of income / furnishing inaccurate particulars of income, levied under Section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year

Income Tax Officer Ward 4(2)(3) Ahmedabad, Ahmedabad vs. Nitinbhai Kanubhai Patel, Ahmedabad

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

ITA 183/AHD/2025[2016-17]Status: FixedITAT Ahmedabad14 Oct 2025AY 2016-17

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : 2016-2017 Ito, Ward-4(2)(3) Shri Nitinbhai Kanubhai Patel Ahmedabad. Vs. Room No.303, 3Rd Floor Aaykar Bhavan Vejalpur, Ahmedabad. Pan : Aaspp 5802 F (Applicant) (Responent) : None Assessee By : Shri Veerabadram Vislavath, Sr.Dr. Revenue By सुनवाई क" तारीख/Date Of Hearing : 13/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 14/10/2025

For Appellant: Shri Veerabadram Vislavath, sr.DR
Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 54BSection 54B(1)(i)

assessed total income at Rs.3,09,00,950/-. Penalty proceedings under section 271(1)(c) were initiated separately for furnishing inaccurate particulars of income. 2.8 Aggrieved, the assessee preferred appeal before the learned CIT(A). Before the learned CIT(A), the assessee filed detailed statement of facts challenging the findings

ACIT-19(1), Mumbai vs. Manohar Kanungo, Mumbai

In the result, the appeal of the Revenue is dismissed and the Cross

ITA 685/MUM/2025[2009-10]Status: DisposedITAT Mumbai14 Oct 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary: A.Y. : 2009-10 C.O. No. 75/Mum/2025 : A.Y. : 2009-10 (Arising Out Of Ita No. 685/M/25)

For Appellant: NONEFor Respondent: Shri Annavaran Kosuri
Section 143(3)Section 145(3)Section 271(1)(c)Section 274

order u/s. 271(1)(c) of the Act dt. 28-03-2019, wherein the AO recorded his satisfaction that the assessee has furnished inaccurate particulars of income by concealing particulars of his income and penalty amount to Rs. 2,19,170/- was levied on the assessee. 6. The assessee carried ... much as the AO failed to specify the particular charge - whether the penalty proceedings were initiated for "concealment of income" or for "furnishing inaccurate particulars of income." It is well-settled by the Hon'ble Bombay High Court in the case of Mohammad Farhan A. Shaikh (supra) that such omnibus

M.Lakhamsi& Co., Mumbai vs. Dy. Commissioner of Income Tax 17(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4304/MUM/2025[2012-13]Status: DisposedITAT Mumbai13 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Mr. Ketan Vajani, CAFor Respondent: Shri Annavaran Kasuri, (Sr. AR)
Section 271(1)(c)Section 274Section 292B

which either did not exist or was never supplied, the assessee had not only concealed particulars of its income, but had also furnished inaccurate particulars of income. "SLP against this decision was dismissed by Hon'ble Supreme Court of India as reported in (2018) 99 taxmann.com ... issued notice u/s 271(1)(c)/274 of the Act, stating that: “you have concealed the particulars of your income by furnishing inaccurate particulars of income.". These are both limbs of the notice, that is, "concealment of income" and for "furnishing inaccurate particulars of income". Therefore, it is abundantly clear

Mukon Construction Private Limited, Mumbai vs. ACIT Circle 7(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1152/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Oct 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Siddharth Srivashtav,ARFor Respondent: Shri Annavaran Kasuri, (Sr. AR)
Section 271Section 271(1)Section 271(1)(c)Section 274Section 292B

which either did not exist or was never supplied, the assessee had not only concealed particulars of its income, but had also furnished inaccurate particulars of income. "SLP against this decision was dismissed by Hon'ble Supreme Court of India as reported in (2018) 99 taxmann.com ... issued notice u/s 271(1)(c)/274 of the Act, stating that: “you have concealed the particulars of your income by furnishing inaccurate particulars of income.". These are both limbs of the notice, that is, "concealment of income" and for "furnishing inaccurate particulars of income". Therefore, it is abundantly clear

Birendra Singh Nirbhay, Sirsi Road Jaipur Rajasthan vs. ITO Ward 3(1) Jaipur, Ncrb Income Tax Department Statue Circle Jaipur Rajasthan

In the result, the appeal of the assessee is allowed

ITA 704/JPR/2024[2015-16]Status: DisposedITAT Jaipur09 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, CAFor Respondent: Shri Shri Gautam Singh Choudhary, JCIT-DR
Section 10(38)Section 132(4)Section 69C

treated as undisclosed expenditure under Section 69C. iv. Separate penalty proceedings under Section 271(1)(c) were initiated for furnishing inaccurate particulars of income and for concealment. 7. Legal and Judicial Reasoning: i. The assessment order emphasizes that in assessing whether a transaction is genuine or sham, the surrounding circumstances

Kanhaiyalal Rameshwar Das, Kota vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

ITA 1454/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 Oct 2025AY 2014-15
For Appellant: Shri Rajnikant Bhatra, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR (Thru: V.C)
Section 132(1)Section 143(3)Section 153Section 154Section 271(1)Section 271(1)(c)

unnecessary portions of the notice. If the Ld. A.O. was of the view that the assessee has concealed the income or furnishing inaccurate particulars of income then he should have deleted or not mentioned the other limb for imposition of penalty i.e. concealing the particulars of income. The above ... should be specific on imposing of penalty u/s 271 (1) (c) of Income Tax Act, 1961 i.e. concealed particulars of income or furnishing inaccurate particulars of income. Reliance is placed on the decision of Hon'ble Karnataka High Court in the case of CIT Vs. M/s SSA's EMERALD MEADOWS

Kanhaiyalal Rameshwar Das, Kota vs. Assistant Commissioner of Income Tax, Central Circle-3, Jaipur

ITA 1453/JPR/2024[2012-13]Status: DisposedITAT Jaipur08 Oct 2025AY 2012-13
For Appellant: Shri Rajnikant Bhatra, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR (Thru: V.C)
Section 132(1)Section 143(3)Section 153Section 154Section 271(1)Section 271(1)(c)

unnecessary portions of the notice. If the Ld. A.O. was of the view that the assessee has concealed the income or furnishing inaccurate particulars of income then he should have deleted or not mentioned the other limb for imposition of penalty i.e. concealing the particulars of income. The above ... should be specific on imposing of penalty u/s 271 (1) (c) of Income Tax Act, 1961 i.e. concealed particulars of income or furnishing inaccurate particulars of income. Reliance is placed on the decision of Hon'ble Karnataka High Court in the case of CIT Vs. M/s SSA's EMERALD MEADOWS

Mr. Arumugasamy Vasantha Vikas, Virdhunagar vs. ITO, Corp. Ward-4, Madurai

In the result, appeals filed by the assessee are allowed and Stay

ITA 2108/CHNY/2025[2011-12]Status: DisposedITAT Chennai08 Oct 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.B. Rama Krishnan, FCAFor Respondent: Mr.Saujanya Ranjan, IRS
Section 271(1)(c)Section 274

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. 3. By raising the aforesaid Ground No.3, the assessee has assailed the action of the Ld.CIT(A) confirming the penalty u/s.271 ... assessee guessing as to what is in the mind of the AO viz whether he proposes concealment of particulars of income or furnishing inaccurate particulars of income. Therefore, the contentions of the Ld.DR cannot be accepted and is held to be devoid of merits and therefore rejected. And since

Mr. Arumugasamy Vasantha Vikas, Virudhunagar vs. ITO, Corp. Ward-4., Madurai, Mudrai

In the result, appeals filed by the assessee are allowed and Stay

ITA 2107/CHNY/2025[2010-11]Status: DisposedITAT Chennai08 Oct 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.B. Rama Krishnan, FCAFor Respondent: Mr.Saujanya Ranjan, IRS
Section 271(1)(c)Section 274

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. 3. By raising the aforesaid Ground No.3, the assessee has assailed the action of the Ld.CIT(A) confirming the penalty u/s.271 ... assessee guessing as to what is in the mind of the AO viz whether he proposes concealment of particulars of income or furnishing inaccurate particulars of income. Therefore, the contentions of the Ld.DR cannot be accepted and is held to be devoid of merits and therefore rejected. And since

Late Jagdish, Jaipur vs. ITO Ward 7(1), Jaipur

ITA 1437/JPR/2024[2007-08]Status: DisposedITAT Jaipur07 Oct 2025AY 2007-08

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Rohan Sogani, C.AFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 271(1)(c)

appellant also tried to camouflage capital gains from sale of immovable property as agricultural property sale. In this matter the appellant furnished inaccurate particulars of income from capital gains. Hence, in this case penalty was proposed for both "Concealment of Income" and for "Furnishing inaccurate particulars of income". Hence

Sanjay Jayantilal Shah, Ahmedabad vs. The ITO, Ward-2(1)(1), Ahmedabad

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

ITA 79/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2014-15

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2014-2015 Sanjay Jayantilal Shah Ito, Ward-2(1)(1) 202/A, Shivalik 10 Vs. Vejalpur Opp: Sbi Zonal Office Ahmedabad. Ambawadi, Ahmedabad 380 015 Pan : Aktps 8891 A (Applicant) (Responent) : Assessee By Shri S.N. Divatia & Shri Samir Vora, Ars. : Shri Kalpesh Rupavatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश/O R D E R आदेश आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 29.11.2024 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As "Cit(A)"], For The Assessment Year 2014–15, Arising Out Of The Assessment Order Dated 31.03.2022 Passed U/S 147 Read With Section 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act") By The National Faceless Assessment Centre, Delhi [Hereinafter Referred To As "Assessing Officer Or Ao"].

Section 10(38)Section 144BSection 147Section 148Section 234ASection 271(1)(c)Section 68Section 69C

against returned income of Rs. 17,25,831/-. The Assessing Officer also initiated penalty proceedings u/s 271(1)(c) for furnishing inaccurate particulars of income and directed charging of interest u/s 234A, 234B and 234C of the Act. 2.6 Aggrieved by the aforesaid assessment, the assessee carried the matter

DCIT 3(3)(1), Mumbai vs. World Series Hockey Private Limited, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 3894/MUM/2023[2012-13]Status: DisposedITAT Mumbai06 Oct 2025AY 2012-13

Bench: Shri Pawan Singh & Smt.Renu Jauhri

For Appellant: NoneFor Respondent: Shri SwapnilChoudhary- Sr. DR
Section 143(3)Section 250Section 271(1)Section 271(1)(c)

confirmed by the Ld. CIT(A) and thus the claim of bad debts of the assessee company is a clear case of furnishing inaccurate particulars of income" The Appellant craves leave to add, amend and/or vary the grounds of Appeal before or during the course of hearing. 3. Brief fact ... during the penalty proceedings by the assessee, ld. AO levied penalty of Rs.2,30,00,000/- after holding that the assessee had furnished inaccurate particulars of income in respect of the bad debts claimed as written off. Against the penalty order dated 28.09.2015, the assessee filed an appeal before

DCIT, Swargate Pune vs. Honeywell Automation India Limited, Pune

ITA 2180/PUN/2024[2010-11]Status: DisposedITAT Pune03 Oct 2025AY 2010-11

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshali

For Appellant: Mr Siddhesh Chougule[‘Ld. AR’]For Respondent: Mr Gaurav Singh [‘Ld. DR’]
Section 10A(7)Section 143(1)Section 143(3)Section 246ASection 250Section 271(1)(c)Section 274

variation as per 26AS the assessee was called upon to showcase as to why penalty for concealing the particulars of income and furnishing inaccurate particulars of income should not be levied. Holding assessee’s explanation unsatisfactory & unconvincing, the Ld. AO levied the penalty equal to 100% of tax sought

Shri. Vijaysingh Madhavrao Patwardhan, Mumbai vs. The Assistant Commissioner of Income Tax-26(1), Mumbai (Now DCIT-41(1)(1), Mumbai)

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

ITA 4993/MUM/2025[2006-07]Status: DisposedITAT Mumbai30 Sept 2025AY 2006-07

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Ms. Vinita Shah (virtually appeared)For Respondent: Ms. Kavitha Kaushik (SR DR)
Section 143(3)Section 147Section 250Section 271(1)(c)Section 69

also initiated penalty proceedings 2 Shri Vijaysingh Madhavrao Patwardhan u/s. 271(1)(c) of the Act, for concealment of income and furnishing inaccurate particulars of income. The ld. AO then passed the penalty order dated 27.08.2015, u/s. 271(1)(c) of the Act, thereby levying a penalty ... furnishing inaccurate particulars of income as being 300% of the tax sought to be evaded. 5. The assessee was in appeal before the first appellate authority, who vide order dated 26.03.2025 dismissed the appeal filed by the assessee and upheld the penalty levied by the ld. AO. 6. The assessee

Ganpat Thakur (Legal Heir of Late Shri Balaram Gopinath Thakur), Raigad vs. I.T.O., Ward-28(1)(2), Mumbai

In the result, both the appeals are allowed for statistical purposes

ITA 1955/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Sept 2025AY 2013-14

Bench: Shri Pawan Singh & Smt. Renu Jauhri

For Appellant: Ms. Ritika AgarwalFor Respondent: Shri Swapnil Choudhary- Sr. AR
Section 142(1)Section 144Section 148Section 154Section 250Section 271(1)(c)Section 274

initiation of penalty is invalid and vague since the AO has not mentioned whether the penalty is for "concealment" or for "furnishing inaccurate particulars of income". P a g e | 3 ITA NO. 1954 & 1955/mum/2025. 3. BECAUSE, the AO has erred in initiating penalty for "concealment of income" but levying ... assessee during penalty proceedings also, ld. AO levied a penalty of Rs. 45,18,148/- u/s. 271(1)(c) for furnishing inaccurate particulars of income. Aggrieved, the assessee preferred appeals before ld. CIT(A) against the assessment as well as the penalty order