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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)

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 214/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2008-09

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

case of CIT vs. Super Steel (Sales) Co. 178 ITR 451 (Calcutta), the High Court held that penalty under Section 271(1)(c) of the Act for concealment of income cannot be levied on the assessee when protective assessment was made in case of assessee and income was actually assessed ... assessee submitted that it is a settled law that penalty under Section 271AAA only can be imposed in “search year” and not penalty under Section 271(1)(c) of the Act. The Counsel for the assessee placed reliance on several judicial precedents on this issue. Accordingly, it was submitted

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 213/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2007-08

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

case of CIT vs. Super Steel (Sales) Co. 178 ITR 451 (Calcutta), the High Court held that penalty under Section 271(1)(c) of the Act for concealment of income cannot be levied on the assessee when protective assessment was made in case of assessee and income was actually assessed ... assessee submitted that it is a settled law that penalty under Section 271AAA only can be imposed in “search year” and not penalty under Section 271(1)(c) of the Act. The Counsel for the assessee placed reliance on several judicial precedents on this issue. Accordingly, it was submitted

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 212/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2006-07

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

case of CIT vs. Super Steel (Sales) Co. 178 ITR 451 (Calcutta), the High Court held that penalty under Section 271(1)(c) of the Act for concealment of income cannot be levied on the assessee when protective assessment was made in case of assessee and income was actually assessed ... assessee submitted that it is a settled law that penalty under Section 271AAA only can be imposed in “search year” and not penalty under Section 271(1)(c) of the Act. The Counsel for the assessee placed reliance on several judicial precedents on this issue. Accordingly, it was submitted

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 211/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2005-06

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

case of CIT vs. Super Steel (Sales) Co. 178 ITR 451 (Calcutta), the High Court held that penalty under Section 271(1)(c) of the Act for concealment of income cannot be levied on the assessee when protective assessment was made in case of assessee and income was actually assessed ... assessee submitted that it is a settled law that penalty under Section 271AAA only can be imposed in “search year” and not penalty under Section 271(1)(c) of the Act. The Counsel for the assessee placed reliance on several judicial precedents on this issue. Accordingly, it was submitted

Shri Rohitji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 210/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

case of CIT vs. Super Steel (Sales) Co. 178 ITR 451 (Calcutta), the High Court held that penalty under Section 271(1)(c) of the Act for concealment of income cannot be levied on the assessee when protective assessment was made in case of assessee and income was actually assessed ... assessee submitted that it is a settled law that penalty under Section 271AAA only can be imposed in “search year” and not penalty under Section 271(1)(c) of the Act. The Counsel for the assessee placed reliance on several judicial precedents on this issue. Accordingly, it was submitted

Dy. Commissioner of Income Tax-13(1)(2), Mumbai vs. Pratham Telecom India Pvt Ltd, Mumbai

ITA 479/MUM/2024[2011-12]Status: DisposedITAT Mumbai31 Jul 2024AY 2011-12

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Parikshit AgarwalFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 271(1)(c)Section 41(1)

notice issued under Section 274 of the Act, it has been stated as follows – “You are requested to show caused why the penalty under section 271(1)(c) should not be levied on you for concealment of particulars of income or furnishing inaccurate particulars of such income”. Clearly, the penalty ... supplied) 8. Thus, the statutory notice issued to the Appellant does not inform the Appellant about the charge against the Appellant – whether penalty under Section 271(1)(c) of the Act is sought to be levied for concealment of particulars of income or furnishing 6 inaccurate particulars of income

M/S Mascot Construction Pvt. Ltd., Mumbai vs. Income Tax Officer, 2(2)(3)

In the result, the appeal of the assessee is allowed

ITA 2737/MUM/2024[2010-11]Status: DisposedITAT Mumbai31 Jul 2024AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2010-11 M/S Mascot Constructions Pvt. Ltd., Income-Tax Officer 2(2)(3), 3Rd Floor, Indian Mercantile Aayakar Bhavan, Vs. Chambers, 14R, Kamani Marg, Mumbai-400020. Ballard Estate, Mumbai-400001. Pan No. Aaccm 6531 H Appellant Respondent

For Appellant: Mr. Haridas Bhat
Section 143(3)Section 250Section 271(1)(c)Section 50C

consider imposition of the penalty under Settlement Commission to consider imposition of the penalty under Settlement Commission to consider imposition of the penalty under Section 271(1) (c) of the Act, yet in the facts of the present case, elem Section 271(1) (c ... case. Accordingly, the writ petition succeeds in tablished in the present case. Accordingly, the writ petition succeeds in part. The levy of penalty under Section 271(1)(c) of the Act under the part. The levy of penalty under Section 271(1)(c) of the Act under the part

Morgan Stanley India Company Private Limited, Mumbai vs. Assistant Commissioner of Income Tax - 4(3)(2), Mumbai

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

ITA 2448/MUM/2024[2012-23]Status: DisposedITAT Mumbai30 Jul 2024AY 2012-23

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Sunil Lala, CAFor Respondent: Shri Nayanjyoti Nath, Sr. DR
Section 115JSection 14ASection 271(1)(c)

section 14A of the Act – (Ground No.2) (iii) Addition of interest income already offered in subsequent year – (Ground No.3) (iv) Initiation of penalty under section 271(1)(c) of the Act – (Ground No.4) Morgan Stanley India Company Ltd. 2. The assessee is a company engaged in the business of providing

Dy Commissioner of Income Tax -5(2)(1), Mumbai vs. Nakodiam Diamonds Private Limited, Mumbai

In the result, all the appeals of the revenue are dismissed

ITA 1812/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Jul 2024AY 2012-13

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhan, Juducial Member

For Appellant: Shri Prateek JainFor Respondent: Shri Ashok Kumar Ambastha, Sr. DR
Section 147Section 148Section 271Section 271(1)Section 271(1)(c)

7141/Mum/2017 held as under: “We have considered rival submissions and perused material on record. At the outset, we must observe that the penalty under section 271(1)(c) or the Act was imposed on the addition or 38,80,265/- representing the quantum of alleged non-genuine purchases. However ... revenue has been taken care of by estimating its profit, there is no need to penalize the assessee any further by imposing penalty under section 271(1)(c) of the Act. More so, when the addition has been finally made on estimate basis. In view of the aforesaid, we have

Dy. Commissioner of Income Tax -5(2)(1), Mumbai vs. Nakodiam Diamonds Private Limited, Mumbai

In the result, all the appeals of the revenue are dismissed

ITA 1783/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Jul 2024AY 2014-15

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhan, Juducial Member

For Appellant: Shri Prateek JainFor Respondent: Shri Ashok Kumar Ambastha, Sr. DR
Section 147Section 148Section 271Section 271(1)Section 271(1)(c)

7141/Mum/2017 held as under: “We have considered rival submissions and perused material on record. At the outset, we must observe that the penalty under section 271(1)(c) or the Act was imposed on the addition or 38,80,265/- representing the quantum of alleged non-genuine purchases. However ... revenue has been taken care of by estimating its profit, there is no need to penalize the assessee any further by imposing penalty under section 271(1)(c) of the Act. More so, when the addition has been finally made on estimate basis. In view of the aforesaid, we have

Dy. Commissioner of Income Tax -5(2)(1), Mumbai vs. Nakodiam Diamonds Private Limited, Mumbai

In the result, all the appeals of the revenue are dismissed

ITA 1766/MUM/2024[2010-11]Status: DisposedITAT Mumbai30 Jul 2024AY 2010-11

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhan, Juducial Member

For Appellant: Shri Prateek JainFor Respondent: Shri Ashok Kumar Ambastha, Sr. DR
Section 147Section 148Section 271Section 271(1)Section 271(1)(c)

7141/Mum/2017 held as under: “We have considered rival submissions and perused material on record. At the outset, we must observe that the penalty under section 271(1)(c) or the Act was imposed on the addition or 38,80,265/- representing the quantum of alleged non-genuine purchases. However ... revenue has been taken care of by estimating its profit, there is no need to penalize the assessee any further by imposing penalty under section 271(1)(c) of the Act. More so, when the addition has been finally made on estimate basis. In view of the aforesaid, we have

ACIT-1(1), Indore vs. Life Care International, Indore

Appeal is dismissed

ITA 411/IND/2023[2011-12]Status: DisposedITAT Indore26 Jul 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2011-12 Assistant Commissioner Of Life Care International, Income-Tax, 37-38, Lasudia Mori, बनाम/ 1(1), Dewas Naka, Vs. Indore. Indore. (Assessee/Appellant) (Revenue/Respondent) Pan: Aabfl5181G Assessee By Shri S.N.Agrawal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.07.2024 Date Of Pronouncement 26.07.2024

Section 143(3)Section 271(1)(c)

separate appeal against penalty-order whereupon the CIT(A) has deleted penalty by concluding thus: “Since the quantum on which the penalty under section 271(1)(c) was levied has been deleted by Hon’ble ITAT, penalty u/s 271(1)(c) of the Act has no basis and is held

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 618/DEL/2022[2013-14]Status: DisposedITAT Delhi26 Jul 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 617/DEL/2022[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 616/DEL/2022[2011-12]Status: DisposedITAT Delhi26 Jul 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 615/DEL/2022[2010-11]Status: DisposedITAT Delhi26 Jul 2024AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 614/DEL/2022[2013-14]Status: DisposedITAT Delhi26 Jul 2024AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 613/DEL/2022[2011-12]Status: DisposedITAT Delhi26 Jul 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 612/DEL/2022[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing

Vishwanath Aggarwal, Delhi vs. The Addl. CIT, Central Range-05, Delhi

The appeals of the assessee are allowed and the penalty is deleted

ITA 611/DEL/2022[2010-11]Status: DisposedITAT Delhi26 Jul 2024AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaitas No.611 To 618/Del/2022 Assessment Years: 2010-11, 2012-13, 2011-12,2013-14, 2010-11, 2011-12, 2012-13 & 2013-14 Vishwanath Aggarwal, Vs Addl. Cit, House No.98, Block C-2, Range-05, Janakpuri, Delhi. New Delhi – 110 058. Pan: Abxpa4825B (Appellant) (Respondent) Assessee By : Shri Sudesh Garg, Advocate & Shri Prince Bansal, Ca Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 04.07.2024 Date Of Pronouncement : .07.2024 Order Per Anubhav Sharma, Jm: These Are Appeals Preferred By The Assessee Against The Orders Of The Commissioner Of Income Tax (Appeals) (Hereinafter Referred To As Ld. First Appellate Authority Or ‘The Ld. Faa’ For Short) In Appeals Filed Before Him Against The Penalty Orders Of The Ld. Assessing Officer (Hereinafter Referred To As The Ld. Ao, For Short). Further Details Of The Penalty Orders Of The Lower Authorities Are As Under:-

For Appellant: Shri Sudesh Garg, Advocate &For Respondent: Ms Sapna Bhatia, CIT-DR
Section 132ASection 153ASection 269SSection 271DSection 271E

proceedings under section 27ID of the Act for violation of section 269SS of the Act. Once the Assessing Officer decided to initiate penalty under section 271(1)(c) of the Act, subsequently, reference was made to Addl. CIT to initiate penalty proceedings under section 271D of the Act, the Assessing