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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)

At Kearney Ltd.- India Branch Office, Gurgaon vs. DCIT, Circle- 1(1)(1), International Taxation, New Delhi

In the result, appeals of the Assessee’s in ITA Nos

ITA 960/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234C and 234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary

At Kearney Ltd.- India Branch Office, Gurgaon vs. DCIT, Circle- 1(1)(1), International Taxation, New Delhi

In the result, appeals of the Assessee’s in ITA Nos

ITA 959/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234C and 234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. A.T. Kearney Ltd., Gurgaon

In the result, appeals of the Assessee’s in ITA Nos

ITA 1306/DEL/2018[2013-14]Status: DisposedITAT Delhi28 Feb 2024AY 2013-14

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234C and 234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. A.T. Kearney Ltd., Gurgaon

In the result, appeals of the Assessee’s in ITA Nos

ITA 1305/DEL/2018[2012-13]Status: DisposedITAT Delhi28 Feb 2024AY 2012-13

Bench: SHRI SHAMIM YAHYA (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 234ASection 271(1)(c)Section 27l

234C and 234D of the Act. That the learned AO has erred, in law and on facts, in 4. proposing to initiate penalty under section 271(1)(c) of the Act. The above Grounds of Appeal are without prejudice to each other. The Appellant craves for leave to amend, vary

Income Tax Officer, Ahmedabad vs. Rajeshri Avas Developers Private Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 758/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad27 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 758/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2013-14) Ito Rajeshri Avas Developers बनाम/ Ward -3(1)(1), Ahmedabad Private Limited Vs. A-9, Anupam Colony, Lbs Road, Opp. Chirag Diamond, Bapunagar, Gujarat 380024 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr9139G .. (अपीलाथ" /Appellant) (""यथ" / Respondent) None अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Ashok Kumar Suthar, Sr. D.R.

For Respondent: Shri Ashok Kumar Suthar, Sr. D.R
Section 143(3)Section 271(1)(c)

Income Tax Act, 1961, (hereinafter referred to as ‘the Act’) for Assessment Year 2013-14. 2. The matter relates to levy of penalty under Section 271(1)(c) of the Act on account of bogus purchase. The assessment under Section 143(3) of the Act was finalized on 26.03.2016 assessing ... that view of the matter, in our considered opinion, since the addition has been deleted by the Ld. Tribunal, the penalty under Section 271(1)(c) of the Act imposed on the basis of such addition has lost ITA No. 758/Ahd/2023 (ITO vs. Rajeshri Avas Developers Private Limited

Marvel Drugs Pvt Ltd., Mumbai vs. ITO-6(3)(3), Mumbai

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

ITA 3626/MUM/2023[2006-07]Status: DisposedITAT Mumbai27 Feb 2024AY 2006-07

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhailassessment Year: 2006-07 M/S. Marvel Drugs Pvt. Ito 6(3)(3), Ltd., Aayakar Bhavan, 20, Nagin Mahal, Vs. Mumbai – 400 020 82 Vn Road, Mumbai – 400 020 Pan: Aaacm4655N (Appellant) (Respondent) Present For: Assessee By : Shri Surendra Nijsure, A.R. Revenue By : Smt Mahita Nair, Sr. D.R. Date Of Hearing : 21.02.2024 Date Of Pronouncement : 27/02/.2024 O R D E R Per : Sandeep Singh Karhail: 1. The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 11/08/2023 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act”) By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“Learned Cit(A)”], For The Assessment Year 2006-07, Which In Turn Arose From The Penalty Order Dated 26/03/2013 Passed Under Section 271(1)(C) Of The Act.

For Appellant: Shri Surendra Nijsure, A.RFor Respondent: Smt Mahita Nair, Sr. D.R
Section 143(3)Section 250Section 271(1)(c)Section 274Section 40

both limbs of 271(1)(c), and therefore the AO failed to record his satisfaction while initiating proceedings for imposition of penalty under section 271(1)(c) as to which limb of the provisions of section 271(1)(c) is attracted. Your appellant craves leave to add to alter ... Grounds of Appeal set out herein above.” 3. The only grievance of the assessee is against the levy of penalty under section 271(1)(c) of the Act. 4. We have considered the submissions of both sides and perused the material available on record. The facts of the case

Deepak Dudeja (L/H of Sh. Manohar Lal), Gurgaon vs. Income Tax Officer, Ward 2(4), Gurgaon

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

ITA 2839/DEL/2023[AY 2011-12]Status: DisposedITAT Delhi27 Feb 2024

Bench: Shri Kul Bharat[Assessment Year : 2011-12] Deepak Dudeja Vs Ito, [Legal Heir Of Late Shri Manohar Ward 2(4), Lal], Cw-66, Malibu Town, Gurgaon. Sohna Road, Gurgaon, Haryana-122018. Pan-Acepl00503F Appellant Respondent Appellant By Ms.Monalisa Maity, Adv. Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 22.02.2024 Date Of Pronouncement 27.02.2024

Section 148Section 234ASection 271(1)(c)

same are emanating out of reassessment proceedings which are bad in law. 6. That the Ld. AO has erred in levying penalty under section 271(1)(c), 271(1)(b) and 271F upon a deceased person. 7. That the Ld. AO has erred in charging interest under section 234A, 234B

Kamal Enterprises and New Life Hospital, Hyderabad vs. DCIT, Circle-9(1), Hyderabad

In the result, appeal of the assessee is allowed

ITA 17/HYD/2024[2016-17]Status: DisposedITAT Hyderabad26 Feb 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri Shakeer Ahamed, DR
Section 24Section 271(1)(c)Section 275

claimed the expenditure, which claim was not accepted or was not acceptable to the Revenue, that by itself would not attract the penalty under Section 271(1)(c) of the Act. It was further held that if the contention of the Revenue is accepted, then in case of every return ... where the claim made is not accepted by the learned Assessing Officer for any reason, the assessee will invite penalty under section 271(1)(c) of the Act and that is clearly not the intendment of the Legislature. Page 5 of 7 11. Merely because the assessee preferred a claim

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-2, Faridabad

Appeal is partly allowed

ITA 2997/DEL/2022[2012-13]Status: DisposedITAT Delhi21 Feb 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-2, Faridabad

Appeal is partly allowed

ITA 2996/DEL/2022[2011-12]Status: DisposedITAT Delhi21 Feb 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-II, Faridabad

Appeal is partly allowed

ITA 2994/DEL/2022[2008-09]Status: DisposedITAT Delhi21 Feb 2024AY 2008-09

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-II, Faridabad

Appeal is partly allowed

ITA 2814/DEL/2018[2012-13]Status: DisposedITAT Delhi21 Feb 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-II, Faridabad

Appeal is partly allowed

ITA 2813/DEL/2018[2011-12]Status: DisposedITAT Delhi21 Feb 2024AY 2011-12

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Rajesh Mangla, Faridabad vs. DCIT, Central Circle-II, Faridabad

Appeal is partly allowed

ITA 2811/DEL/2018[2008-09]Status: DisposedITAT Delhi21 Feb 2024AY 2008-09

Bench: Shri Saktijit Dey & Shri M. Balaganesh

Section 132Section 153(1)(a)Section 153ASection 271(1)(c)

additions so made were confirmed by learned First Appellate Authority. Based on these additions, the Assessing Officer initiated proceeding for imposition of penalty under section 271(1)(c) of the Act and ultimately passed an order imposing penalty of Rs.12,41,689/-. The penalty so imposed was confirmed by learned ... record. While deciding the quantum appeal of the assessee, being ITA No.2813/Del/2018 (supra), we have deleted the addition based on which penalty under section 271(1)(c) of the act was imposed. That being the case, the penalty imposed cannot survive. Accordingly, we delete it. 25. In the result, appeal

Sharad Bhaskarrao Gaikwad, Nashik vs. Income Tax Officer, Nashik

In the result, appeal of the assessee is allowed

ITA 917/PUN/2023[2016-17]Status: DisposedITAT Pune19 Feb 2024AY 2016-17

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.917/Pun/2023 िनधा"रण वष" / Assessment Year :2016-17 Sharad Bhaskarrao Gaikwad, The Income Tax T.No.1, Vanai Apartment, V Officer, Gangapur Road, Behind S Nashik. Kulswamini Apart, Nashik – 422005. Pan: Adspg2339R Appellant/ Assessee Respondent /Revenue Assessee By Miss Abhilasha Sanjay Pawar-Ca, Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 14/02/2024 Date Of Pronouncement 19/02/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 02.05.2023 Emanating From Penalty Order Dated 17.02.2022 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 Submission Of Ld.Ar : 2. The Ld.Authorised Representative(Ld.Ar) Of The Assessee Filed Written Submission. Vide Written Submission Ld.Ar Invited Our Sharad Bhaskarrao Gaikwad [A] Attention To The Notice Dated 24.03.2021 For A.Y. 2016-17 Issued By Assessing Officer(Ao) Which Was The First Notice With Reference To The Penalty. Ld.Ar In The Written Submission Explained That Nowhere In The Notice Section 271(1)(C) Is Mentioned. Nowhere In The Notice, The Assessing Officer Has Clarified, Whether It Is For Concealment Of Income Or For Filing Inaccurate Particulars.

Section 147Section 250Section 271(1)(c)

Thus, it explains that there is no application of mind by the Assessing Officer. Primarily, the Assessing Officer has not initiated penalty under section 271(1)(c) as the section is not mentioned in the notice dated 24.03.2021. Also the charge is not specified. 4.2.1 We have already mentioned that

Rupinder Kaur, New Delhi vs. DCIT Central Circle-30, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2002/DEL/2023[2012-13]Status: DisposedITAT Delhi19 Feb 2024AY 2012-13

Bench: Shri Shamim Yahyarupinder Kaur, Vs. Dcit, Central Circle 30, R-675, 1St Floor, New Delhi. New Rajinder Nagar, Central Delhi, New Delhi – 110 060. (Pan : Aaspk0367J) (Appellant) (Respondent) Assessee By : Shri Lalit Mohan, Ca Shri Parth Singhal, Advocate Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 14.02.2024 Date Of Order : 19.02.2024

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 271(1)(c)Section 274

directed against the order of the ld. CIT (Appeals)-30, New Delhi dated 18.01.2023 for the assessment year 2012-13 confirming the penalty under section 271(1)(c) of the Income-tax Act, 1961 (for short ‘the Act’) amounting to Rs.15,22,861/-.. 2. At the outset, it is noted

DCIT, New Delhi vs. M/S Sahar Airlines Ltd., New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1969/DEL/2013[1992-93]Status: DisposedITAT Delhi19 Feb 2024AY 1992-93

Bench: Shri G.S. Pannu, Vice- & Shri Challa Nagendra Prasadassessment Year: 2013-14

Section 143(3)

period under consideration and assessment shall be completed at NIL income. Issue notice of demand and challan and issued notice of penalty under Section 271(1)(c).” 5. The assessee preferred an appeal before the learned CIT (Appeals) and the learned CIT (Appeals) considering the averments of the Assessing Officer

DCIT, Circle 2(1)(1), Bangalore vs. Eka Software Solutions Private Limited, Bangalore

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

ITA 977/BANG/2023[2011-12]Status: DisposedITAT Bangalore14 Feb 2024AY 2011-12

Bench: Shri George George K & Shri Chandra Poojarind Shri Laxmi Prasad Sahuassessment Year : 2011-12 Dcit, Vs. M/S. Eka Software Solutions Pvt. Ltd., Circle – 2(1)(1), Building 2A, East Tower, Bengaluru. Vrindavan Tech Village, Outer Ring Road, Devarbeesanhalli Village, Varthur Hobli, Bengaluru – 575 001. Pan : Aabce 3660 Q Appellant Respondent Assessee By : Shri. Ajay Rotti, Ca Revenue By : Ms. Neera Malhotra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.02.2024 Date Of Pronouncement : 14.02.2024

For Appellant: Shri. Ajay Rotti, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 250Section 271(1)(c)Section 274

issued show cause notice under section 274 of the Act directing the assessee to show cause as to why penalty under section 271(1)(c) of the Act should not be levied. Since there was no response by the assessee to the several notices issued ... sought to be evaded amounting to Rs.2,12,32,907/-. 5. Aggrieved by the Order of the AO in imposing penalty under section 271(1)(c) of the Act, assessee filed appeal before the First Appellate Authority. The CIT(A) allowed the appeal of the assessee. The CIT(A) held

Meyer Organics Private Limited, Mumbai vs. National Faceless Appeal Centre, Mumbai

In the result, the appeal by the assessee is allowed

ITA 3307/MUM/2023[2011-12]Status: DisposedITAT Mumbai12 Feb 2024AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Mihir C. Naniwadekar a/wFor Respondent: Smt. Mahita Nair
Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 274

delete any of the grounds taken in this appeal.” 3. The only grievance of the assessee is against the levy of penalty under section 271(1)(c) of the Act. 4. The brief facts of the case are that the assessee is a company and is engaged in the business ... view of the aforesaid findings, we are of the considered view that this is not a fit case for the levy of penalty under section 271(1)(c) of the Act. Accordingly, the ground raised in the present appeal is allowed and the AO is directed to delete the penalty

Shri Shivajirao R.Chavan, Ahmedabad vs. The Income Tax Officer, Ward-13(2), Ahmedabad

The appeals of the assessee are allowed

ITA 435/AHD/2005[1996-1997]Status: DisposedITAT Ahmedabad05 Feb 2024AY 1996-1997

Bench: Smt.Annapurna Gupta & Smt. Madhumita Roy

For Appellant: Shri Sakar Sharma, A.RFor Respondent: Ms. Saumya Pandey Jain, Sr.DR
Section 147Section 148Section 148(2)Section 250(6)Section 271(1)(c)

threeappeals of the assessee in ITA No.1751- 1753/Ahd/2008 are in relation to the orders passed by the ld.CIT(A) confirming levy of penalty under section 271(1)(c) of the Income Tax Act, 1961 [hereinafter referred to as "the Act" for short]. Remaining appeals are in relation to orders passed