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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)

Biren Dhirajlal Shah, Gandhinagar vs. CIT(A), Gandhinagar

In the result the appeal filed by the assessee in ITA No

ITA 190/AHD/2024[2008-09]Status: DisposedITAT Ahmedabad03 Apr 2025AY 2008-09

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No: 194/Ahd/2021 &\nITA No: 190/Ahd/2024\nAssessment Year: 2008-09\nBiren Dhirajlal Shah\nPlot No. 441-1, Sector-22\nNr. Police Chowkey,\nGandhinagar-382021\nPAN: ACSPS5653F\n(Appellant)\nAssessee Represented: Shri Chetan Agarwal, A.R. &\nMs. Krupa Panchal, CA\nRevenue Represented:\nDate of hearing\nDate of pronouncement\nShri Alpesh Parmar, Sr. D.R.\n: 19-03-2025\n: 03-04-2025\nIncome Tax Officer,\nWard-1,\nV

Section 144Section 17Section 271(1)(c)

passed by the Commissioner of Income Tax (Appeals), Gandhinagar arising out of the exparte assessment orders passed under section 144 and penalty under section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act') relating to the Assessment Year 2008-09. I.T.A No. 194/Ahd/2021

Biren Dhirajlal Shah, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result the appeal filed by the assessee in ITA No

ITA 194/AHD/2021[2008-09]Status: DisposedITAT Ahmedabad03 Apr 2025AY 2008-09

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No: 194/Ahd/2021 &\nITA No: 190/Ahd/2024\nAssessment Year: 2008-09\nBiren Dhirajlal Shah\nPlot No. 441-1, Sector-22\nNr. Police Chowkey,\nGandhinagar-382021\nPAN: ACSPS5653F\n(Appellant)\nIncome Tax Officer,\nWard-1,\nVs Gandhinagar\n(Respondent)\nAssessee Represented: Shri Chetan Agarwal, A.R. &\nMs. Krupa Panchal, CA\nRevenue Represented:\nShri Alpesh Parmar, Sr. D.R.\nDate of hearing\n: 19-03-2025\nDate of

Section 144Section 17Section 271(1)(c)

passed by the Commissioner of Income Tax (Appeals), Gandhinagar arising out of the exparte assessment orders passed under section 144 and penalty under section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act') relating to the Assessment Year 2008-09. 2. The registry

Shobha Ramakrishnana Nair, Ernakulam vs. ITO, Ward 2, Aluva

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

ITA 810/COCH/2024[2016-17]Status: DisposedITAT Cochin02 Apr 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Keshav Dubeyassessment Year: 2016-17 Shobha Ramakrishnan Nair Karthika Sebipuram Ito Ernakulam Ward-2 Vs. Manjapra So Aluva Kerala 683581 Pan No :Awrpr5406L Appellant Respondent Appellant By : None Respondent By : Smt. Leena Lal, Sr. D.R. Date Of Hearing : 30.01.2025 Date Of Pronouncement : 02.04.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 22.12.2023 Vide Din & Order No. Itba/Nfac/S/250/2023-24/1059003947(1) For The Ay 2016- 17 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Smt. Leena Lal, Sr. D.R
Section 250

from the Shobha Ramakrishnan Nair, Manjapra, Kerala Page 9 of 12 Income tax Officer, ward 2, Aluva, proposing levy of penalty under section 271(1)(c)of the Act. It appears that all notices/communications addressed to her were sent to the earlier email id, which belonged to her staff

Ramdas Pandharinath Kale(HUF), Pune vs. ITO, Ward-12(3), Pune

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

ITA 246/PUN/2025[2013-14]Status: DisposedITAT Pune28 Mar 2025AY 2013-14

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.246/Pun/2025 िनधा"रण वष" / Assessment Year: 2013-14 Ramdas Pandharinath Kale V The Income Tax Officer, (Huf), S Ward-12(3), Pune. Wagjholi, Kalewasti, Kasanand Road, Haveli, Pune – 412207. Pan: Aaqhr7916A Appellant/ Assessee Respondent /Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 27/03/2025 Date Of Pronouncement 28/03/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Delhi U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 19.10.2024 For The A.Y.2013-14. The Assessee Has Raised The Following Grounds Of Appeal : “Each Ground Is Taken Without Prejudice To Each Other.

Section 143(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 54

circumstances of the case and in law and ITA No.246/PUN/2025 [A] The learned AD has erred in imposing the penalty under section 271(1)(c) without considering the submission made by assessee and the id CIT A erred in confirming the same 2. The learned AO has erred in invoking ... same needs to be set aside or cancelled 4 Without following principles of natural justice the AO has erred in imposing penalty under section 271(1)(c) of the Income Tax Act. On the facts and circumstances of the case and in law the order of penalty under Section 271

Vineet Thakar, Navi Mumbai vs. ITO(41)(4)(4), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6098/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Mar 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Prabhash Shankar

For Appellant: Shri Devendra Jain,ARFor Respondent: Ms. Kavitha Kaushik (Sr. DR)
Section 147Section 234ASection 271(1)(c)Section 69A

Explanation 3 to section 271(1)(c) of the Act, we are of the considered view that the AO correctly levied a penalty under section 271(1)(c) of the Act in the present case and the same has been rightly upheld by the learned CIT(A). In light ... aforesaid findings, we find no infirmity in the impugned order in upholding the levy of penalty under section 271(1)(c) of the Act. As a result, the impugned order is upheld and the grounds raised by the assessee are dismissed.” 5.4 Thus, in the light of aforesaid discussions

Brindaban III Co Operative Housing Society Limited, Mumbai vs. ITO Ward-24(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 6064/MUM/2024[2012-13]Status: DisposedITAT Mumbai28 Mar 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2012-13 Brindaban Iii Co-Operative Income Tax Officer, Ward- Housing Society Ltd., 24(1)(1), Mumbai Poonam Nagar, Mahakali Caves Vs. Road, Andheri East, Mumbai – 400 093 (Pan : Aabab2518A) (Appellant) (Respondent) Present For: Assessee : Shri Kinjal Bhuta, Advocate Revenue : Ms. Monika H. Pande, Sr.Dr

For Appellant: Shri Kinjal Bhuta, AdvocateFor Respondent: Ms. Monika H. Pande, Sr.DR
Section 143(3)Section 148Section 271(1)(c)Section 292B

However, following survey proceedings, the assessee filed revised return disclosing gain on sale of shares as business income. The Assessing Officer imposed penalty under section 271(1)(c). The Commissioner (Appeals) and the Tribunal deleted the penalty. Hon'ble Court held that the Commissioner (Appeals) reached a prima facie conclusion

Cornerstone Ondemand Limited, Mumbai vs. ACIT(It)-2(1)(1), Mumbai

ITA 5677/MUM/2024[2019-20]Status: DisposedITAT Mumbai28 Mar 2025AY 2019-20

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

dated 03.09.2024 for AY 2019-20. The common issues contended by the assessee in all the appeals pertain to levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 (the Act) for AY 2015-16 & 2016-17 and levy of penalty under section 270A ... 5677/Mum/2024 Cornerstone Ondemand Limited ITA No.3747/Mum/2024 - AY 2015-16 3. For the purpose of adjudicating the levy of penalty under section 271(1)(c) of the Act we will consider the appeal filed by the assessee for AY 2015-16 as a lead case

Connerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3753/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

dated 03.09.2024 for AY 2019-20. The common issues contended by the assessee in all the appeals pertain to levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 (the Act) for AY 2015-16 & 2016-17 and levy of penalty under section 270A ... 5677/Mum/2024 Cornerstone Ondemand Limited ITA No.3747/Mum/2024 - AY 2015-16 3. For the purpose of adjudicating the levy of penalty under section 271(1)(c) of the Act we will consider the appeal filed by the assessee for AY 2015-16 as a lead case

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3752/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Mar 2025AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

dated 03.09.2024 for AY 2019-20. The common issues contended by the assessee in all the appeals pertain to levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 (the Act) for AY 2015-16 & 2016-17 and levy of penalty under section 270A ... 5677/Mum/2024 Cornerstone Ondemand Limited ITA No.3747/Mum/2024 - AY 2015-16 3. For the purpose of adjudicating the levy of penalty under section 271(1)(c) of the Act we will consider the appeal filed by the assessee for AY 2015-16 as a lead case

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-2(1)(1), Mumbai

ITA 3751/MUM/2024[2016-17]Status: DisposedITAT Mumbai28 Mar 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

dated 03.09.2024 for AY 2019-20. The common issues contended by the assessee in all the appeals pertain to levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 (the Act) for AY 2015-16 & 2016-17 and levy of penalty under section 270A ... 5677/Mum/2024 Cornerstone Ondemand Limited ITA No.3747/Mum/2024 - AY 2015-16 3. For the purpose of adjudicating the levy of penalty under section 271(1)(c) of the Act we will consider the appeal filed by the assessee for AY 2015-16 as a lead case

Cornerstone Ondemand Limited, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation )-291)(1), Mumbai

ITA 3747/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Mar 2025AY 2015-16

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Hiten Thakkar, AR
Section 270ASection 271(1)(c)

dated 03.09.2024 for AY 2019-20. The common issues contended by the assessee in all the appeals pertain to levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 (the Act) for AY 2015-16 & 2016-17 and levy of penalty under section 270A ... 5677/Mum/2024 Cornerstone Ondemand Limited ITA No.3747/Mum/2024 - AY 2015-16 3. For the purpose of adjudicating the levy of penalty under section 271(1)(c) of the Act we will consider the appeal filed by the assessee for AY 2015-16 as a lead case

Rakesh Bhatt, New Delhi vs. ACIT Central Circle-18, New Delhi

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

ITA 1181/DEL/2023[2016-17]Status: DisposedITAT Delhi28 Mar 2025AY 2016-17

Bench: Shris.Rifaur Rahmanbhl Forex & Finlease Limited, Vs. Dcit, Central Circle - 2, 6, Mohan Singh Place, New Delhi. Connaught Place, New Delhi – 110 001. (Pan : Aabcb8886H) (Appellant) (Respondent) Assessee By : Ms. Gini Gandhi, Advocate Ms. Anu Bajaj, Advocate Revenue By : Shri Sanjay Kumar, Sr. Dr Date Of Hearing : 13.03.2025 Date Of Order : 14.05.2025 O R D E R 1. The Assessee Has Filed This Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short] Dated 11.07.2023 For The Assessment Year 2014-15. 2. At The Time Of Hearing, Ld. Ar Of The Assessee Submitted That The Appeal Filed By The Assessee Is Against Imposition Of Penalty Under Section 271(1)(C) Of The Income-Tax Act, 1961 (For Short ‘The Act’). In This Regard, He Submitted That Assessee Has Filed Its Original Return Of Income U/S 139(4) Of The Act Which Was Belated Return & Declared The Loss. As Per The Provisions Of The Act, The Losses Declared In The Belated Returns

For Appellant: Ms. Gini Gandhi, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 139Section 139(4)Section 147Section 148Section 14ASection 271(1)(c)

time of hearing, ld. AR of the assessee submitted that the appeal filed by the assessee is against imposition of penalty under section 271(1)(c) of the Income-tax Act, 1961 (for short ‘the Act’). In this regard, he submitted that assessee has filed its original return of income

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 536/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Mar 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 535/MUM/2025[2014-15]Status: DisposedITAT Mumbai27 Mar 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5 (2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 470/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Mar 2025AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 469/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Mar 2025AY 2013-14

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 468/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Mar 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 467/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Mar 2025AY 2011-12

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Priyaa Mohan Gurnani, Navi Mumbai vs. ITO Central Circle 5(2), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 466/MUM/2025[2010-11]Status: DisposedITAT Mumbai27 Mar 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153ASection 271(1)(c)Section 275

being 100% of tax sought to have been allegedly concealing the particulars of income. Similar orders were passed by the Ld.AO levying penalty under section 271(1)(c ) for all the years under consideration. Against the penalty orders passed by the Ld.AO, the assessee preferred appeal for all the assessment ... correct computation is not filed or that which is filed is not accurate, then the assessee would be liable to penalty under section 271(1)(c) of the Act. The expression 'has concealed the particulars of income' has not been defined Act. According to Law Lexicon, the word "conceal" means

Rajasthan Prime Steel Processing Center Pvt. Ltd., Alwar vs. DCIT, Circle- 15(1), New Delhi

Accordingly, the grounds relevant to this issue raised by the Revenue stand dismissed in both years

ITA 3293/DEL/2018[2010-11]Status: DisposedITAT Delhi27 Mar 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 271(1)(c)

Assessee’s appeals (ITA No.3292 & 3293/Del/2018): i. Addition on account of ALP adjustment [All grounds except the last one] ii. Initiation of penalty under section 271(1)(c) of the Act [Last ground] Revenue’s appeals (ITA No.3537 & 3538/Del/2018): i. Exclusion of preoperative and or non-recurring expenses; such