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“penalty under section 271(1)(c)”

PenaltySection 271(1)(c)Section 271(1)(c)1,699 judgments

The decision most relied on for penalty under section 271(1)(c) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on penalty under section 271(1)(c)

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 penalty under section 271(1)(c)

Arun Kumar Sarup, Mumbai vs. Dy. Commissioner of Income Tax Circle 1(1)(1), Mumbai

In the result, all the three appeals are treated as allowed for statistical purposes

ITA 4709/MUM/2025[2015-2016]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-2016

Bench: Hon’Ble Shri Sandeep Gosain& Shri Prabhash Shankararun Kumar Sarup Vs. Dy. Commissioner Of 2Nd Floor, Amartara Pvt. Ltd. Income Tax Circle Saki Vihar Road, Powai, 1(1)(1), Mumbai Mumbai – 400072. 553, 5Th Floor, Aaykar Bhavn, Maharshi Karve Road, Mumbai - 400020 Pan/Gir No. Aahps2384Q (Applicant) (Respondent)

Section 250Section 271(1)(c)Section 69

order. Copies of few letters etc. for my medical history is enclosed. 5. I had received a show cause notice of penalty under section 271(1)(c) of Income Tax Act, 1961 on 23/07/2025 and then I realize the lapse in filing the appeal in I.T.A.T. and I immediately approached

Prasam Rakesh Choudhary, Girnar Society, Bapurao Galli, Itwari, Nagpur vs. Deputy Commissioner of Income Tax, Central -1, Bhopal

Appeal is dismissed

ITA 529/IND/2025[2018 -2019]Status: HeardITAT Indore22 Dec 2025

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271(1)(c) is a civil liability. Willful concealment is not an essential ingredient for attracting civil liability? 3. Whether on facts and in the circumstances ... these discussions and considering settled position of law laid down in this regard, I hold that AO is not correct in levying penalty under section 271(1)(c) of the Act in the appellant's case. Accordingly, the penalty levied of Rs. 2,00,00,000/- stands deleted. Ground

Assistant Commissioner of Income Tax Circle-1(1), Bhopoal, Bhopal vs. M/S Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan, Bhopal

Appeal is dismissed

ITA 509/IND/2025[2014-15]Status: DisposedITAT Indore22 Dec 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniacit Circle-1(1) M/S. Rashtriya Takniki Bhopal Shikshak Prashikshan Evam Anunsandhan Sansthan बनाम/ Samiti, Vs. Bhopal (Revenue/Appellant) (Assessee/Respondent) Pan: Aabar2266H Assessee By Shri Ashish Porwal, Sr. Dr Revenue By Shri Vinod Joshi, Ar Date Of Hearing 08.12.2025 Date Of Pronouncement 22.12.2025

Section 10Section 271(1)(c)Section 43(1)

Rashtriya Takniki Shikshak Prashikshan Evam Anunsandhan Sansthan ITA No. 509/Ind/2025 – AY 2014-15 271(1)(c) holding that "The penalty under Section 271(1)(c) is a civil liability. Willful concealment is not an essential ingredient for attracting civil liability? 3. Whether on facts and in the circumstances ... these discussions and considering settled position of law laid down in this regard, I hold that AO is not correct in levying penalty under section 271(1)(c) of the Act in the appellant's case. Accordingly, the penalty levied of Rs. 2,00,00,000/- stands deleted. Ground

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2175/PUN/2025[2013-14]Status: DisposedITAT Pune22 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2174/PUN/2025[2014-15]Status: DisposedITAT Pune22 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word 12 ITA Nos.2169 to 2175/PUN/2025 "inaccurate" signified a deliberate act or omission ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2173/PUN/2025[2012-13]Status: DisposedITAT Pune22 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2172/PUN/2025[2010-11]Status: DisposedITAT Pune22 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2171/PUN/2025[2009-10]Status: DisposedITAT Pune22 Dec 2025AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Kolhapur vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2170/PUN/2025[2008-09]Status: DisposedITAT Pune22 Dec 2025AY 2008-09

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Shri Datta Shetkari Sahakari Sakhar Karkhana Ltd, Shirol vs. DCIT, Cir-1, Kolhapur

In the result the appeal filed by the assessee in ITA

ITA 2169/PUN/2025[2007-08]Status: DisposedITAT Pune22 Dec 2025AY 2007-08

Bench: Shri Manish Borad & Shri Vinay Bhamoresl.

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143(3)Section 271(1)(c)Section 274Section 40A(2)(a)

terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee ... ultimate inference in Dilip N. Shroff's case (supra) to the effect that mens rea was an essential ingredient for the penalty under section 271(1)(c) that the decision in Dilip N. Shroff's case (supra) was overruled. 9. We are not concerned in the present case with

Visakhapatnam Industrial Water Supply Company Limited, Visakhapatnam vs. DCIT, Circle-5(1), Visakhapatnam

In the result, the appeal by the assessee is allowed

ITA 657/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2012-13

Bench: Shri Sandeep Singh Karhail, Hon’Ble & Shri Omkareshwar Chidara, Hon’Bleआयकर अपील सं./I.T.A. No. 657/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2012-13) Visakhapatnam Industrial Water V. Dy. Cit – Circle – 5(1) Supply Company Limited Visakhapatnam Gvmc Room No.204 Tenneti Bhavan, Asilmetta Junction Visakhapatnam – 530002 Andhra Pradesh [Pan: Aabcv2240H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(2)Section 143(3)Section 250Section 263Section 271(1)(C)Section 271(1)(c)Section 43B

such notice is invalid. Ld. CIT(A) vide impugned order dismissed the appeal filed by the assessee and upheld the levy of penalty under section 271(1)(c) of the Act, by observing as follows: - “9.4 During the appellate proceedings, the appellant objected that penalty levied on the basis ... limbs is sought to be pressed into service and both the limbs cannot be permitted to be clubbed for levying the penalty under section 271(1)(c) of the Act. Accordingly, respectfully following the decision of Page No. 8 I.T.A. No. 657/VIZ/2025 Visakhapatnam Industrial Water Supply Company Limited

U.P.Cooperative Federationltd, Lucknow vs. ITO-2(3), Lucknow

In the result, the appeal of the assessee is dismissed

ITA 260/LKW/2023[2003-14]Status: DisposedITAT Lucknow19 Dec 2025AY 2003-14

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.260/Lkw/2023 ननिाारण वर्ा/ Assessment Year: 2003-04 U.P. Cooperative Federation V. Income Tax Officer-2(3) Ltd Pratyaksh Kar Bhawan, Pcf Building, 32, Station Road, 57, Ram Tirath Marg, Lucknow-226004. Hazratganj, Lucknow- 226001. Pan:Aaaau0373P अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri D. D. Chopra, Advocate प्रत्यर्थी कक और से /Respondent By: Shri Neeraj Kumar, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 22 09 2025 घोर्णा कक तारीख/ Date Of 19 12 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri D. D. Chopra, AdvocateFor Respondent: Shri Neeraj Kumar, CIT(DR)
Section 142Section 142(2)(a)Section 153(2)(a)Section 271Section 80PSection 80P(2)

been passed on 25.8.2014. e. It is further submitted that the Assessing officer on the basis of assessment order dtd.9.6.2006 had levied penalty under section 271(1)(c)of the Act on the present appellant vide order dated 31.3.2008. In appeal, the learned Commissioner (Appeal) vide order dated 26.8.2010 while

Classic Share & Stock Broking Services Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(1), Mumbai

In the result, appeal filed by the assessee stands dismissed

ITA 4962/MUM/2025[2012-13]Status: DisposedITAT Mumbai18 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain, () & Shri Girish Agrawal, ()

Section 250Section 271(1)(c)Section 274

circumstances of the case and in law, the CIT(A) ought not to have confirmed the levy of the impugned penalty under section 271(1)(c) of the Act. The appellants further, contend that on the facts and in the circumstances of the case and in law, the impugned notice

Rohini Maruti Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1839/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

income. It was claimed that mere disallowance of the claim in the assessment proceedings could not be the sole basis for levying penalty under section 271(1)(c) of the Act. It was submitted specifically that it was an investment company and in its own case for assessment year ... Amol Vasant Deshmukh & Ors.) income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf

Tulsabai Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1838/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

income. It was claimed that mere disallowance of the claim in the assessment proceedings could not be the sole basis for levying penalty under section 271(1)(c) of the Act. It was submitted specifically that it was an investment company and in its own case for assessment year ... Amol Vasant Deshmukh & Ors.) income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf

Amol Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1837/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

income. It was claimed that mere disallowance of the claim in the assessment proceedings could not be the sole basis for levying penalty under section 271(1)(c) of the Act. It was submitted specifically that it was an investment company and in its own case for assessment year ... Amol Vasant Deshmukh & Ors.) income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under section 271(1)(c), mens rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf

Foods and Inns Limited, Mumbai vs. DCIT, Circle 2(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4926/MUM/2025[2015-16]Status: DisposedITAT Mumbai15 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Nitin KulkarniFor Respondent: Ms. Kavita Kaushik, Sr. DR
Section 143(3)Section 271(1)Section 271(1)(c)Section 36(1)(iii)

assessee against the quantum addition. 3.2 Consequently, the Assessing Officer issued a show-cause notice dated 30.11.2021 proposing levy of penalty under section 271(1)(c) of the Act. The Assessing Officer observed that the assessee had claimed interest expenditure on borrowed funds utilised for acquisition of capital assets, which ... line of business. It was, therefore, argued that the claim was a debatable one and disallowance thereof could not ipso facto attract penalty under section 271(1)(c). Reliance was placed on the judgment of the Hon'ble Supreme Court in CIT v. Reliance Petroproducts

Blue Ridge Unit B Tower 9 to 14, Pune vs. ITO, Ward-2(4), Pune

In the result, appeal of the assessee in ITA No

ITA 2387/PUN/2025[2017-18]Status: DisposedITAT Pune12 Dec 2025AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2385, 2386 & 2387/Pun/2025 निर्धारण वषा / Assessment Years: 2015-16, 2016-17 & 2017-18 Blue Ridge Unit B Tower 9 Vs The Income Tax Officer, To 14 Co-Operative Housiong Ward-2(4), Pune. Society Ltd., Unit B Society Office, Rajiv Gandhi It Park, Phase I, Hinjewadi, Pune – 411057. Maharashtra. Pan: Aacab2693P Appellant/ Assessee Respondent / Revenue Assessee By Ms.Ayesha Ansari & Shri Sandesh Ps – Ar’S Revenue By Shri Harish Bist – Addl.Cit(Through Virtual Hearing) Date Of Hearing 01/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16, 2016-17 & 2017-18 All Dated 26.08.2024 Emanating From The Separate Assessment Orders Passed Under Section 147 R.W.S

Section 147Section 250Section 7(1)Section 80PSection 80P(2)(d)Section 80P(4)

merit basis instead dismissed the appeal without considering substantial legal and factual questions raised. warranting intervention by this Hon'ble Tribunal. 7. Penalty under Section 271(1)(c) is unjustified and bad in law: 7.1 BECAUSE there was no malafide intention, concealment of income, or furnishing of inaccurate particulars

Blue Ridge Unit B Tower 9 to 14, Pune vs. ITO, Ward-2(4), Pune

In the result, appeal of the assessee in ITA No

ITA 2386/PUN/2025[2016-17]Status: DisposedITAT Pune12 Dec 2025AY 2016-17

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2385, 2386 & 2387/Pun/2025 निर्धारण वषा / Assessment Years: 2015-16, 2016-17 & 2017-18 Blue Ridge Unit B Tower 9 Vs The Income Tax Officer, To 14 Co-Operative Housiong Ward-2(4), Pune. Society Ltd., Unit B Society Office, Rajiv Gandhi It Park, Phase I, Hinjewadi, Pune – 411057. Maharashtra. Pan: Aacab2693P Appellant/ Assessee Respondent / Revenue Assessee By Ms.Ayesha Ansari & Shri Sandesh Ps – Ar’S Revenue By Shri Harish Bist – Addl.Cit(Through Virtual Hearing) Date Of Hearing 01/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Bunch Of Three Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16, 2016-17 & 2017-18 All Dated 26.08.2024 Emanating From The Separate Assessment Orders Passed Under Section 147 R.W.S

Section 147Section 250Section 7(1)Section 80PSection 80P(2)(d)Section 80P(4)

merit basis instead dismissed the appeal without considering substantial legal and factual questions raised. warranting intervention by this Hon'ble Tribunal. 7. Penalty under Section 271(1)(c) is unjustified and bad in law: 7.1 BECAUSE there was no malafide intention, concealment of income, or furnishing of inaccurate particulars

Blue Ridge Unit B Tower 9 to 14, Pune vs. ITO, Ward-2(4), Pune

In the result, appeal of the assessee in ITA No

ITA 2385/PUN/2025[2015-16]Status: DisposedITAT Pune12 Dec 2025AY 2015-16
Section 147Section 250Section 7(1)Section 80PSection 80P(2)(d)Section 80P(4)

merit basis instead dismissed the appeal without considering substantial legal and factual questions raised. warranting intervention by this Hon'ble Tribunal. 7. Penalty under Section 271(1)(c) is unjustified and bad in law: 7.1 BECAUSE there was no malafide intention, concealment of income, or furnishing of inaccurate particulars