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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)

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1111/SRT/2025[2012-13]Status: DisposedITAT Surat27 Feb 2026AY 2012-13

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section 271(1)(c) of Income Tax Act, 1961 not mentioned. 3. 2. On the facts and circumstances of the case ... submits that the Assessing Officer made addition in quantum assessment on estimation basis. It is admitted position under the law that no penalty under Section 271(1)(c) of the Act is leviable on estimated additions. The ld. AR prayed to delete the entire penalty. 5. On the other hand

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1110/SRT/2025[2011-12]Status: DisposedITAT Surat27 Feb 2026AY 2011-12

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section 271(1)(c) of Income Tax Act, 1961 not mentioned. 3. 2. On the facts and circumstances of the case ... submits that the Assessing Officer made addition in quantum assessment on estimation basis. It is admitted position under the law that no penalty under Section 271(1)(c) of the Act is leviable on estimated additions. The ld. AR prayed to delete the entire penalty. 5. On the other hand

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1109/SRT/2025[2010-11]Status: DisposedITAT Surat27 Feb 2026AY 2010-11

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section 271(1)(c) of Income Tax Act, 1961 not mentioned. 3. 2. On the facts and circumstances of the case ... submits that the Assessing Officer made addition in quantum assessment on estimation basis. It is admitted position under the law that no penalty under Section 271(1)(c) of the Act is leviable on estimated additions. The ld. AR prayed to delete the entire penalty. 5. On the other hand

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1108/SRT/2025[2009-10]Status: DisposedITAT Surat27 Feb 2026AY 2009-10

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section 271(1)(c) of Income Tax Act, 1961 not mentioned. 3. 2. On the facts and circumstances of the case ... submits that the Assessing Officer made addition in quantum assessment on estimation basis. It is admitted position under the law that no penalty under Section 271(1)(c) of the Act is leviable on estimated additions. The ld. AR prayed to delete the entire penalty. 5. On the other hand

Sun Diam, Surat vs. ITO 2(3)(6), Surat

In the result, appeal of the assessee is allowed

ITA 1107/SRT/2025[2008-09]Status: DisposedITAT Surat27 Feb 2026AY 2008-09

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 271Section 271(1)(c)

1)(c) of the Income Tax Act, 1961 on the basis of invalid penalty notice in which the limb of levy of penalty under section 271(1)(c) of Income Tax Act, 1961 not mentioned. 3. 2. On the facts and circumstances of the case ... submits that the Assessing Officer made addition in quantum assessment on estimation basis. It is admitted position under the law that no penalty under Section 271(1)(c) of the Act is leviable on estimated additions. The ld. AR prayed to delete the entire penalty. 5. On the other hand

Kapil Khandelwal, Bareilly, Uttar Pradesh vs. Asst. Commissioner of Income Tax, Circle-I, Bareilly, Uttar Pradesh

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

ITA 335/LKW/2025[2015-16]Status: DisposedITAT Lucknow27 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Kapil Khandelwal, Vs. Asstt. Commissioner Of 56, Moar Kothi, Gangapur, Bareilly Income Tax, Circle-I, Bareilly Pan: Aiypk4908M (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 27.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961, Wherein The Ld. Cit(A) Has Confirmed The Penalty Levied Upon The Assessee Under Section 271(1)(C) By The Ld. Ao On 17.03.2022 & Dismissed The Appeal Of The Assessee For The A.Y. 2015-16. The Grounds Of Appeal Are As Under: - “1. Because Requisite Satisfaction For Levy Of Penalty U/S 271(1)(C) If The Income Tax Act 1961 Was Not Recorded In The Regular Assessment Order Dated 22.12.2017 Passed A/S 100%, Therefore, Penalty Proceedings Got Wholly Vitiated & Consequently, The Id. "Cit(A)" Ought To Have Quashed The Penalty Order Dated 17.03.2022, Being Illegal, Bad-In-Law & Without Jurisdiction 2. Because The Show Cause Notice For Levy Of Penalty Under Section 271(1)(C) Of The Act Did Not Specify Under Which Limb Penalty Was Sought To Be Imposed I.E.. Whether On Account Of Concealment Of Income Or For Furnishing Inaccurate Particulars Of Income & Consequently, The Penalty Order Dated 17.03.2022 Passed By Faceless Assessing Officer Deserved To Be Quashed.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 10(38)Section 250Section 271(1)(c)

penalty order dated 17.03.2022, being illegal, bad-in-law and without jurisdiction 2. BECAUSE the show cause notice for levy of penalty under section 271(1)(c) of the Act did not specify under which limb penalty was sought to be imposed i.e.. whether on account of concealment ... dismissal of the appeal of the assessee, the ld. AO also took up the case of the assessee for levy of penalty under section 271(1)(c) which had been kept in abeyance prior to the same. The assessee submitted that it had not concealed any particulars of income

Karur Sree Rama Trading Pvt.Ltd., Karur vs. ITO, Circle-191), Trichy

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

ITA 3841/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3841/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Karur Sree Rama Trading Pvt. Ltd., Vs. The Income Tax Officer, S.F. No. 2262, Pari Nagar, Chinna Circle 1(1), Andan Koil Road, Karur 639 001. Trichy. [Pan:Aabfs8790C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 26.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13 Passed Under Section 147/271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 144Section 147Section 271(1)(c)Section 274

penalty proceedings initiated in the original assessment order dated 31.03.2015. Under the above facts and circumstances, we quash the order of levying penalty under section 271(1)(c) of the Act. Thus, the ground Nos. 2 to 5 raised by the assessee are allowed. Since the assessee is required

Amber Corporation, Kalyan vs. ITO Ward 3(1), Kalyan, Thane

In the result the Assessee’s Appeal is allowed

ITA 8373/MUM/2025[2010-2011]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-2011

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11

For Appellant: Shri. Hitesh ShahFor Respondent: Shri. Surendra Mohan (SR. DR.)
Section 250Section 271Section 271(1)(c)Section 274

limb/charge for initiating the penalty proceedings and held as under: 16. It is well settled that the condition precedent for levy of penalty under Section 271(1)(c) is only when the Assessing Officer, in the course of proceedings, is satisfied that an assessee has concealed the particulars

M/S.Allied Digital Services Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 1(3), Mumbai

In the result the Assessee‟s Appeal is allowed

ITA 8147/MUM/2025[2010-11]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11 M/S. Allied Digital Services Deputy Commissioner Of Limited, Income Tax, Central 808, 8Th Floor, Mafatlal Centre, Circile 1(3), 905,9Th Floor, Nariman Point, Vs. Mumbai – 400021. Old Cgo Building, Pan – Aaaca5509K Pratishtha Bhavan, M.K. Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Ms. Vinita Shah, Ld. A.R. Revenue By : Shri Surendra Mohan, Sr. D.R. Date Of Hearing : 12.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short „The Act‟) For The A.Y. 20101-11. 2. In The Instant Case, The Ao Vide Assessment Order Dated 28.03.2013 Under Section 143 (3) R.W.S. 153(A) Of The Act Has Made The Additions Of Rs.5,35,91,882/- & Rs.1,25,66,049/- On Account Of Disallowances Under Section 69C Of The Act & Section 2 M/S. Allied Digital Services Limited

For Appellant: Ms. Vinita Shah, Ld. A.RFor Respondent: Shri Surendra Mohan, Sr. D.R
Section 143Section 2Section 250Section 271(1)(c)Section 274Section 69C

limb/charge for initiating the penalty proceedings and held as under: 16. It is well settled that the condition precedent for levy of penalty under Section 271(1)(c) is only when the Assessing Officer, in the course of proceedings, is satisfied that an assessee has concealed the particulars

Paranjyothi Thota, Hyderabad vs. ACIT, Circle-5(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 2079/HYD/2025[2012-13]Status: DisposedITAT Hyderabad25 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

For Appellant: Advocate C. AnuragFor Respondent: Dr. Sachin Kumar, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 50C

Paranjyothi Thota taking note of the relevant facts and also taking into account addition made towards capital gains levied penalty under section 271(1)(c) of the Act for Rs.2,63,269/- which is 100% of tax sought to be evaded. 18. Aggrieved by the penalty order, the assessee preferred ... assessable in the hands of the assessee. Therefore, we find no error on the order of the A.O to levy penalty under section 271(1)(c) of the Act. Thus, we are inclined to uphold the order Ld. CIT (A) and dismiss the appeal filed by the assessee

Paranjyothi Thota, Hyderabad vs. ACIT, Circle-5(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 2050/HYD/2025[2012-13]Status: DisposedITAT Hyderabad25 Feb 2026AY 2012-13

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2050 & 2079/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2012-13) Smt. Paran Jyothi Thota Vs. Asstt. Cit Hyderabad Circle 5(1) Pan:Ajqpt7772F Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Advocate C. Anurag रधजस् व द्वधरध/Revenue By: Dr. Sachin Kumar, Sr. Dr सुिवधई की तधरीख/Date Of Hearing: 12/02/2026 घोर्णध की तधरीख/Pronouncement: 25/02/2026 आदेश/Order Per Manjunatha, G. A.M. These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 09/09/2025 & 25/09/2025, For The Assessment Year 2012-13. Page 1 Of 33

For Appellant: Advocate C. AnuragFor Respondent: Dr. Sachin Kumar, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 50C

Paranjyothi Thota taking note of the relevant facts and also taking into account addition made towards capital gains levied penalty under section 271(1)(c) of the Act for Rs.2,63,269/- which is 100% of tax sought to be evaded. 18. Aggrieved by the penalty order, the assessee preferred ... assessable in the hands of the assessee. Therefore, we find no error on the order of the A.O to levy penalty under section 271(1)(c) of the Act. Thus, we are inclined to uphold the order Ld. CIT (A) and dismiss the appeal filed by the assessee

Health Biotech Limited, Chandigarh vs. Deputy Commissioner of Income Tax, Circle 1(1), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 987/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh24 Feb 2026AY 2014-15

Bench: the disposal of the same.

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 271(1)(c)Section 274Section 40

payable. The Revenue has also not disputed that the assessee continued to be taxed under MAT at the same amount. 9.4 Penalty under section 271(1)(c) is a civil liability, but it is nevertheless attracted only where the conduct of the assessee shows an attempt to conceal income

M/S Mumbadevi Veyhicles, Mumbai vs. ITO Ward 41(4)(2), Mumbai

In the result the appeal of the assessee is allowed

ITA 7899/MUM/2025[2014-15]Status: DisposedITAT Mumbai24 Feb 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Mumbadevi Ito Ward 41(4)(2), Veyhicles Room No. 854B, 8Th Shop No. 18, Suyash Vs. Floor, Kautilya Shopping Centre, Nnp, A. Bhavan, Bkc, K. Vaidya Marg, Goregaon Bandra (East), (E), Mumbai-400 065 Mumbai-400 051 Pan/Gir No. Aaofm0851F (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya & Ms. Sruti Kalyanikar, Ld. Ars Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 24.02.2026

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 151Section 250Section 271(1)(c)

particulars of income. Separate penalty proceedings under section 271F were also initiated for failure to file return under section 139. 6. Thereafter, penalty under section 271(1)(c) was levied vide order dated 29.09.2022, wherein the Assessing Officer imposed a penalty of Rs. 12,51,564/- holding that the assessee ... case of Association of Oral Maxillofacial Surgeons of India vs. ITO (Exemptions), ITA No.274/PUN/2023. In the said case, while dealing with penalty under section 271(1)(c), the Co-ordinate Bench examined the applicability of Explanation 3 and further held that even where the return was filed only in response

Dwarka Cement Works Limited(Converted Into Dwarka Cement Works LLP W.E.F 15-09-2022), Mumbai vs. The Income Tax Officer, Ward-6(2)(1), Mumbai

ITA 6706/MUM/2025[2015-2016]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-2016

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 139(1)Section 143(3)Section 148Section 250Section 271(1)(c)Section 274

income to the extent of Rs. 1,14,95,901/- 6. On the aforesaid basis, the Assessing Officer initiated and subsequently levied penalty under section 271(1)(c) of the Act at 100% of the tax sought to be evaded, and imposed a penalty of Rs. 37,29,845/- vide ... placed upon the decision of the Hon'ble Supreme Court in Union of India v. Dharamendra Textile Processors to hold that penalty under section 271(1)(c) is a civil liability and that willful concealment is not an essential ingredient. 12. As regards the additional ground relating to non specification

DCIT, Circle-1, Ranchi vs. Central Coalfield Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 223/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate

DCIT, Circle-1, Ranchi vs. Central Coalfields Limited, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 220/RAN/2024[2012-13]Status: DisposedITAT Ranchi20 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 32

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate

DCIT, Circle-1, Ranchi vs. Central Coalfield Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 218/RAN/2024[2011-12]Status: DisposedITAT Ranchi20 Feb 2026AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

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

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate

DCIT, Circle-1, Ranchi vs. Central Coalfields Ltd, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 217/RAN/2024[2010-11]Status: DisposedITAT Ranchi20 Feb 2026AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate

M/S. Central Coalfields Ltd., Ranchi vs. DCIT Circle-1, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 213/RAN/2024[2013-14]Status: DisposedITAT Ranchi20 Feb 2026AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 40

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate

M/S. Central Coalfields Ltd., Ranchi vs. DCIT Circle-1, Ranchi

In the result, appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 212/RAN/2024[2012-13]Status: DisposedITAT Ranchi20 Feb 2026AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Central Coalfields Ltd., D.C.I.T., Darbhanga House, Kutchery Road, Circle-1, Vs. Ranchi-834001 (Jharkhand) Ranchi. Pan No. Aaacc 7476 R Appellant/ Assessee Respondent/ Revenue D.C.I.T., Central Coalfield Ltd., Circle-1, 4Th Floor, Central Revenue Building Vs. Ranchi. Annexee, 5A, Main Road, Ranchi-834001 (Jharkhand) Pan No. Aaacc 7476 R Appellant/ Revenue Respondent/ Assessee

Section 271Section 271(1)(c)Section 274Section 32

Manjunath case (supra) concluded as under: "CONCLUSION 63. In the light of what is stated above, what emerges is as under: (a) Penalty under Section 271(1) (c) is a civil liability. (b) not an essential element for imposing penalty for breach of civil obligations or liabilities. (c) Willful concealment ... that is later found to be unsustainable in law, but where all the facts are fully disclosed, does not automatically attract a penalty under Section 271(1)(c) of the Income-tax Act, 1961. The core principle was that the details furnished in the return must be factually inaccurate