← All Phrases

“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)

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 211/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

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

ITA 210/RAN/2024[2010-11]Status: DisposedITAT Ranchi20 Feb 2026AY 2010-11

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

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 209/RAN/2024[2009-10]Status: DisposedITAT Ranchi20 Feb 2026AY 2009-10

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

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

ITA 208/RAN/2024[2008-09]Status: DisposedITAT Ranchi20 Feb 2026AY 2008-09

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

Section 143(3)Section 14ASection 2Section 271Section 271(1)(c)

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. 10 M/s CCL Vs DCIT (b) not an essential element for imposing penalty for breach of civil obligations ... 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 207/RAN/2024[2006-07]Status: DisposedITAT Ranchi20 Feb 2026AY 2006-07

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

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 Coalfield Ltd, Ranchi

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

ITA 206/RAN/2024[2009-10]Status: DisposedITAT Ranchi20 Feb 2026AY 2009-10

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

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

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

ITA 163/RAN/2024[2006-07]Status: DisposedITAT Ranchi20 Feb 2026AY 2006-07

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayd.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 M/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

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

Kiran Bala Gupta, Hyderabad vs. ITO, Ward-10(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 341/HYD/2025[2012-13]Status: DisposedITAT Hyderabad20 Feb 2026AY 2012-13

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.341/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2012-13) Smt. Kiran Bala Gupta, Vs. Income Tax Officer, Hyderabad. Ward-10(1), Pan: Ahvpg6893K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Av Raghuram, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 20/12/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/08/2022 For The Assessment Year (Ay) 2012-13. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: Ms. Aditi Goyal, Sr. AR
Section 10(38)Section 143(2)Section 143(3)Section 271(1)(c)

submitted that once an appeal is admitted by the Hon’ble High Court, then the issue becomes debatable and no penalty under section 271(1)(c) of the Act can be levied. The Ld. AR to buttress his contention had relied upon the judgment of the Hon’ble High Court ... appeal and formulated the substantial question of law arising from the quantum addition, then the issue necessarily becomes debatable and, consequently, the penalty under section 271(1)(c) of the Act is not leviable in respect of such addition. Our aforesaid view is fortified by the judgment

Chandan Dhingadmal Jain, Mumbai, Maharashtra vs. ITO, Ward 19(1)(1), Mumbai, Maharashtra

In the result, both the appeals by the assessee are allowed

ITA 8074/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Feb 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

years 2010-11 and 2011-12. 2. The only grievance of the assessee, in the present appeals, is against the levy of penalty under section 271(1)(c) of the Act. 2 ITAs No.8073 & 8074/Mum/2025 (A.Ys. 2010-11 & 2011-12) 3. We have considered the submissions and perused the material ... consideration. The learned Addl./Joint 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. 3 ITAs No.8073 & 8074/Mum/2025 (A.Ys. 2010-11 & 2011-12) 5. Thus, it is evident from the record that

Chandan Dhingadmal Jain, Mumbai vs. ITO, Ward 19(1)(1), Mumbai, Maharashtra

In the result, both the appeals by the assessee are allowed

ITA 8073/MUM/2025[2010-11]Status: DisposedITAT Mumbai19 Feb 2026AY 2010-11
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)

consideration. The learned Addl./Joint 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. ITAs No.8073 & 8074/Mum/2025 (A.Ys. 2010-11 & 2011-12) 3 5. Thus, it is evident from the record that ... Rubber Industries, reported in [2014] 360 ITR 580 (Raj.), held that where an addition is made purely on an estimate basis, no penalty under section 271(1)(c) of the Act is leviable. Similar view has been expressed by the Hon'ble Punjab & Haryana High Court in CIT v/s Sangrur

Shiv Ratan Education Society, Haridwar vs. ITO Exemption Ward, Dehradun

In the result, the appeal of the assessee is allowed

ITA 184/DDN/2025[2020-21]Status: DisposedITAT Dehradun18 Feb 2026AY 2020-21

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 270ASection 270A(9)(a)Section 9

which claim was not accepted or was not acceptable to the Revenue, that by itself would not, in our opinion, attract the penalty under Section 271(1)(c). If we accept the contention of the Revenue then in case of every Return where the claim made is not accepted ... Assessing Officer for any reason, the assessee will invite penalty under Section 271(1)(c). That is clearly not the intendment of the Legislature.” 7. The Hon’ble Supreme Court in the case of Pricewaterhouse Coopers vs CIT reported in 348 ITR 306 (SC) has held as under: 17. Having

M/S. R R Industries Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

ITA 2743/CHNY/2025[2010-11]Status: DisposedITAT Chennai18 Feb 2026AY 2010-11

Bench: Shri Aby T. Varkey & Ms. Padmavathy. Sआयकर अपील सं./Ita Nos.2741 To 2743/Chny/2025 निर्धारणवर्ष/Assessment Year: 2008-09 To 2010-11 M/S. Rr Industries Ltd., No.94/95, Thiru Vi Ka Industrial Estate, Guindy, Chennai-600 032. [Pan: Aaacr 3594 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Dcit, Central Circle-1(4), Chennai. (प्रत्यर्थी/Respondent) : Mr.M.K. Rangaswamy, Ca : Ms.R. Anitha, Addl.Cit : 11.02.2026 : 18.02.2026 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), (Hereinafter In Short 'The Ld.Cit(A)'), Chennai-18, Dated 07.08.2025, For The Assessment Year (Hereinafter In Short 'Ay') 2008-09 To 2010-11 Confirming The Penalty- Imposed U/S.271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act'). :: 2 ::

Section 10ASection 143(3)Section 153CSection 271(1)(c)Section 274

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

Income Tax Officer-41.2.2, Mumbai vs. In Coach Builders, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 7993/MUM/2025[2009-10]Status: DisposedITAT Mumbai18 Feb 2026AY 2009-10

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailincome Tax Officer, Ward – 41(2)(2) Room No.834, 8Th Floor, Kautilya Bhawan, Bandra Kurla Complex, Mumbai - 400051 ............... Appellant Pan: Aaafi5110R V/S In Coach Builders, Plot No.1A, L.B.S Marg, Vikhroli (W), ……………… Respondent Mumbai- 400083

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69

assessment year 2009-10. 2 2. The only grievance of the Revenue, in the present appeal, is against the deletion of penalty under section 271(1)(c) of the Act. 3. We have considered the submissions of both sides and perused the material available on record. The brief facts ... Rubber Industries, reported in [2014] 360 ITR 580 (Raj.), held that where an addition is made purely on an estimate basis, no penalty under section 271(1)(c) of the Act is leviable. Similar view has been expressed by the Hon'ble Punjab & Haryana High Court in CIT v/s Sangrur

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2616/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

assessee’s appeal in ITA No. 2612/Ahd/2025 (quantum additions) and ITA No. 2613/Ahd/2025 for A.Y. 2015-16 (appeal against imposition of penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal ... Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271(1)(c) of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

assessee’s appeal in ITA No. 2612/Ahd/2025 (quantum additions) and ITA No. 2613/Ahd/2025 for A.Y. 2015-16 (appeal against imposition of penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal ... Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271(1)(c) of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2614/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

assessee’s appeal in ITA No. 2612/Ahd/2025 (quantum additions) and ITA No. 2613/Ahd/2025 for A.Y. 2015-16 (appeal against imposition of penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal ... Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271(1)(c) of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2613/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

assessee’s appeal in ITA No. 2612/Ahd/2025 (quantum additions) and ITA No. 2613/Ahd/2025 for A.Y. 2015-16 (appeal against imposition of penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal ... Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271(1)(c) of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2612/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

assessee’s appeal in ITA No. 2612/Ahd/2025 (quantum additions) and ITA No. 2613/Ahd/2025 for A.Y. 2015-16 (appeal against imposition of penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal ... Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271(1)(c) of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT-2(3)(1), Mumbai

ITA 7704/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

Appellant therefore prays that the aforesaid addition be deleted.” I.T.A. No. 7704/Mum/2025 (Penalty Appeal) 1. GROUND NO. 1: LEVY OF PENALTY UNDER SECTION 271(1)(C) OF THE ACT IS BAD IN LAW: 1.1. On the facts and in the circumstances of the case

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT- 2(3)(1), Mumbai

ITA 7703/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

Appellant therefore prays that the aforesaid addition be deleted.” I.T.A. No. 7704/Mum/2025 (Penalty Appeal) 1. GROUND NO. 1: LEVY OF PENALTY UNDER SECTION 271(1)(C) OF THE ACT IS BAD IN LAW: 1.1. On the facts and in the circumstances of the case