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“penalty u/s 271(1)(c)”

PenaltySection 271(1)(c)Section 271(1)(c)2,277 judgments

The decision most relied on for penalty u/s 271(1)(c) is CIT v. Atul Mohan Bindal (9 SCC 589), cited in 200 judgments on BharatTax.

Leading authorities on penalty u/s 271(1)(c)

CIT v. Atul Mohan Bindal
9 SCC 589 · 2009 · Supreme Court
200
citing judgments

The Supreme Court clarifies the scope of penalty under Section 271(1)(c), holding that for its applicability, conditions stated in the provision must strictly exist, and making an incorrect claim in law does not automatically amount to furnishing inaccurate particulars of income.

CIT v. Subhash Trading Co. Ltd.
221 ITR 110 · 1996 · High Court
146
citing judgments

Penalty under Section 271(1)(c) of the Income Tax Act cannot be levied when an addition to income is based purely on an estimate, without concrete evidence proving concealment of income or furnishing of inaccurate particulars.

Prasanna Dugar v. CIT
70 Taxmann.com 175 · 2016 · Supreme Court
49
citing judgments

Penalty under section 271(1)(c) can be levied even if the assessee voluntarily discloses income after detection by the department or subsequent to a search, especially when the explanation provided is not bona fide or cannot be substantiated.

Ganga Iron & Steel Trading Co. v. Commissioner of Income Tax
135 Taxmann.com 244 · 2022 · High Court
45
citing judgments

A notice imposing penalty under section 271(1)(c) of the Income Tax Act is invalid if it shows non-application of mind by the Assessing Officer regarding the specific grounds for levying the penalty.

CIT v. Dhillon Rice Mills
256 ITR 447 · 2002 · High Court
30
citing judgments

Penalty under section 271(1)(c) is not leviable when additions to income are made on the basis of estimation, rather than on concrete evidence of concealment. Deletion of such a penalty is upheld.

ACIT v. Gebilal Kanhaialal HUF
348 ITR 561 · 2012 · Supreme Court
28
citing judgments

Section 271AAA penalty deletion can be based on the Apex Court's decision in ACIT v. Gebilal Kanhaialal HUF (2012) 348 ITR 561, particularly when there was no specific question put to the assessee about the manner of earning undisclosed income.

CIT v. Norton Electronics Systems (P) Ltd.
41 Taxmann.com 280 · 2014 · High Court
27
citing judgments

Penalty under Section 271(1)(c) is not sustainable when the income addition is made on an estimated basis without clinching material suggesting concealment or inaccurate particulars.

New Holland Tractors (India) (P.) Ltd. v. CIT
49 Taxmann.com 573 · 2014 · High Court
24
citing judgments

The charge of concealment of income and furnishing of inaccurate particulars of income may overlap. A taxpayer's conduct can be considered bonafide even if their submissions were rejected in the quantum appeal.

Judgments citing penalty u/s 271(1)(c)

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result, the appeals of the revenue stands dismissed, and the

ITA 1170/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. M/S Gokul Kripa Colonizers & Developers Pvt. Ltd., Jaipur

In the result, the appeals of the revenue stands dismissed, and the

ITA 1167/JPR/2025[2017-18]Status: DisposedITAT Jaipur13 Nov 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

The Gharthoon Agri Cultural Service Society, Kangra, Himachal Pradesh vs. Income Tax Officer, Ward - Palampur, Himachal Pradesh, Palampur

In the result, appeal is allowed

ITA 928/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh13 Nov 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vinod Kumar Chaudhary, Sr.DR
Section 144Section 147Section 148Section 271(1)(b)Section 271(1)(c)Section 271F

quash the penalty imposed upon the assessee. 9. In the result, appeal is allowed. 10. This appeal emerges out from levy of penalty u/s 271(1)(c) of the Income Tax Act on account of concealment of income. 11. The appeal is time barred by 138 days before the ld.CIT

The Gharthoon Agri Cultural Services Society, Palampur, Himachal Pradesh vs. Income Tax Officer, Ward - Palampur, Himachal Pradesh, Palampur

In the result, appeal is allowed

ITA 926/CHANDI/2025[2015-16 ]Status: DisposedITAT Chandigarh13 Nov 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vinod Kumar Chaudhary, Sr.DR
Section 144Section 147Section 148Section 271(1)(b)Section 271(1)(c)Section 271F

quash the penalty imposed upon the assessee. 9. In the result, appeal is allowed. 10. This appeal emerges out from levy of penalty u/s 271(1)(c) of the Income Tax Act on account of concealment of income. 11. The appeal is time barred by 138 days before the ld.CIT

The Gharthoon Agri Cultural Services Society, Kangra, Himachal Pradesh vs. Income Tax Officer, Ward - Palampur, Himachal Pradesh, Palampur

In the result, appeal is allowed

ITA 925/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh13 Nov 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vinod Kumar Chaudhary, Sr.DR
Section 144Section 147Section 148Section 271(1)(b)Section 271(1)(c)Section 271F

quash the penalty imposed upon the assessee. 9. In the result, appeal is allowed. 10. This appeal emerges out from levy of penalty u/s 271(1)(c) of the Income Tax Act on account of concealment of income. 11. The appeal is time barred by 138 days before the ld.CIT

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1935/KOL/2025[2012-2013]Status: DisposedITAT Kolkata13 Nov 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1931, 1932, 1934 & 1935/Kol/2025 Assessment Years: 2008-09, 2009-10, 2012-13 & 2012-13 Ujjal Sinha……………….……..……………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kol- 700019.. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata….……..……………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 05.08.25, 05.08.25, 04.08.25 & 04.08.25 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Confirming Penalty U/S 271(1)(C) Of The Act Levied By The Assessing Officer. Since The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”] confirming penalty u/s 271(1)(c) of the Act levied by the Assessing Officer. Since the issues involved in all the appeals are common and relate to the same assessee, therefore, these appeals have been ... said order, the assessee preferred appeal before the ld. CIT(A), wherein, the appeal of the assessee has been dismissed and the penalty u/s 271(1)(c) as made by the Assessing Officer was confirmed by ld. CIT(A). 4. Being aggrieved, the assessee is in appeal before

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1934/KOL/2025[2012-2013]Status: DisposedITAT Kolkata13 Nov 2025AY 2012-2013

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1931, 1932, 1934 & 1935/Kol/2025 Assessment Years: 2008-09, 2009-10, 2012-13 & 2012-13 Ujjal Sinha……………….……..……………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kol- 700019.. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata….……..……………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 05.08.25, 05.08.25, 04.08.25 & 04.08.25 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Confirming Penalty U/S 271(1)(C) Of The Act Levied By The Assessing Officer. Since The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”] confirming penalty u/s 271(1)(c) of the Act levied by the Assessing Officer. Since the issues involved in all the appeals are common and relate to the same assessee, therefore, these appeals have been ... said order, the assessee preferred appeal before the ld. CIT(A), wherein, the appeal of the assessee has been dismissed and the penalty u/s 271(1)(c) as made by the Assessing Officer was confirmed by ld. CIT(A). 4. Being aggrieved, the assessee is in appeal before

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1932/KOL/2025[2009-2010]Status: DisposedITAT Kolkata13 Nov 2025AY 2009-2010

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1931, 1932, 1934 & 1935/Kol/2025 Assessment Years: 2008-09, 2009-10, 2012-13 & 2012-13 Ujjal Sinha……………….……..……………………….……….……….……Appellant 57/3, Ballygunge Circular Road, Ballygunge S.O, Kol- 700019.. [Pan: Aeips4499F] Vs. Dcit, Central Circle-4(1), Kolkata….……..……………….....……...…..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Lata Goyal, Ca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 28, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 05.08.25, 05.08.25, 04.08.25 & 04.08.25 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Confirming Penalty U/S 271(1)(C) Of The Act Levied By The Assessing Officer. Since The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order.

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”] confirming penalty u/s 271(1)(c) of the Act levied by the Assessing Officer. Since the issues involved in all the appeals are common and relate to the same assessee, therefore, these appeals have been ... said order, the assessee preferred appeal before the ld. CIT(A), wherein, the appeal of the assessee has been dismissed and the penalty u/s 271(1)(c) as made by the Assessing Officer was confirmed by ld. CIT(A). 4. Being aggrieved, the assessee is in appeal before

Ujjal Sinha, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

In the result, all the captioned appeals of the assessee are allowed

ITA 1931/KOL/2025[2008-2009]Status: DisposedITAT Kolkata13 Nov 2025AY 2008-2009

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 139(1)Section 143(2)Section 153ASection 24Section 250Section 271(1)(c)Section 274

passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred o as the “Act”] confirming penalty u/s 271(1)(c) of the Act levied by the Assessing Officer. Since the issues involved in all the appeals are common and relate to the same assessee, therefore, these appeals have been ... said order, the assessee preferred appeal before the ld. CIT(A), wherein, the appeal of the assessee has been dismissed and the penalty u/s 271(1)(c) as made by the Assessing Officer was confirmed by Id. CIT(A). 4. Being aggrieved, the assessee is in appeal before

Uttam Ghewarchand Shrishrimal, Mumbai vs. Income Tax Officer - 19(3)(5), Matru Mandir

In the result, appeal filed by the assessee is allowed in above terms

ITA 3861/MUM/2025[2010-11]Status: DisposedITAT Mumbai13 Nov 2025AY 2010-11

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanuttam Ghewarchand Vs. Ito-19(3)(5) Shrisharimal Matru Mandir, Grant Road, 13/21, 3Rd Floor, Office No. 307, Seth Mumbai-400 007 Virchand, Umersey Building, 3Rd Panjarpole Lane, Near Cp Tank, Mumbai-400 004 Pan: Acwpj4359F (Appellant) (Respondent)

Section 142(1)Section 143(1)Section 144Section 148Section 250Section 271(1)(c)

last known address of the assessee, but the same could not be served and returned by post. Accordingly, the AO imposed the penalty u/s 271(1)(c) of the Act i.e. the minimum penalty being 100% of the tax sought to be evaded which came ... following order was passed by the Coordinate Bench:- Uttam Ghewarchand Shrisharimal “In the present appeal assessee has contested imposition of penalty u/s 271(1)(c). When a query was made by the bench regarding the status of quantum proceeding, Ld. counsel for assessee submitted that till date assessee

M/S Nandlal Keshardeo, Ranchi vs. ACIT, Central Circle (1), Ranchi

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

ITA 15/RAN/2025[2016-2017]Status: DisposedITAT Ranchi12 Nov 2025AY 2016-2017

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 132(1)Section 132(4)Section 153ASection 271(1)(c)Section 271ASection 274

provided u/s 271 AAB of the Act. The Ld. A.O has very casually used the proforma used for issuing notice before levying penalty u/s 271(1)(c) of the Act for the concealment of income or furnishing of inaccurate particulars of income. Except mentioning the Section 271AAB

Anjani Kumar, Patna vs. ITO, Ward-6(5), Patna

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

ITA 201/PAT/2025[2011-12]Status: DisposedITAT Patna12 Nov 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 250Section 271(1)(c)

same and accordingly, the appeal of the assessee was dismissed. Meanwhile the Ld. AO had initiated penalty proceedings and subsequently imposed penalty u/s 271(1)(c) of the Act for concealment of income. Aggrieved with the penalty order, the assessee filed an appeal before the Ld. CIT(A) who issued

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in not adjudicating the ground of initiating penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in not adjudicating the ground of initiating penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in not adjudicating the ground of initiating penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in not adjudicating the ground of initiating penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

Under the facts and circumstances of the case and in law, Ld. CIT (A) erred in not adjudicating the ground of initiating penalty u/s 271(1)(c) of the Act 13. The appellant craves leave to add, amend, alter, revise and modify any of the grounds of appeal on, before

Vimal Alloys Pvt Ltd, Mandi Gobindgarh vs. Dc/ACIT, Circle, Gobindgarh

In the result, appeal of the assessee is allowed

ITA 684/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh12 Nov 2025AY 2014-15

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 684/Chd/2025 "नधा"रण वष" / Assessment Year: 2014-15 Vimal Alloys Pvt. Ltd., The Dc/Acit, V-Saunti, Amloh Road, Vs Circle, Mandi Gobindgarh. Mandi Gobindgarh. "थायी लेखा सं./Pan No: Aaacv7801M अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Vipen Sethi, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 09.10.2025 Date Of Pronouncement : 12.11.2025 Physical Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 143(3)Section 254Section 271(1)Section 271(1)(c)

whereby income of the assessee was determined at Rs.1,09,53,555/-. The AO, thereafter, visited the assessee with penalty u/s 271(1)(c) of the Act vide his order dated 13.03.2020.He imposed a penalty @ 200% at Rs.32,49,546/-. 4. Dissatisfied with this penalty, assessee filed an appeal before

Somnath Ramdas Jadhav, Ahmednagar vs. ITO Ward 2, Ahmednagar

In the result, the appeal filed by the assessee in ITA

ITA 441/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

Since we have already quashed the quantum assessment order which formed the very basis for levy of penalty u/s 271(1)(c) of the Act, the above penalty does not survive. Consequently, the penalty u/s 271(1)(c) of the Act is hereby deleted. Accordingly, the appeal in ITA No.1092/PUN/2025 ... involving the issue of penalty u/s 271(1)(c) of the Act is allowed. ITA Nos.1089 & 1093/PUN/2025, A.Ys.2015-16 & 2016-17: 16. Since the facts and issues involved in the appeal of the assessee for the assessment year 2013-14 are identical to the facts of the case

Somnath Ramdas Jadhav, Ahmednagar vs. ITO, Ward 2, Ahmednagar

Accordingly, the appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed

ITA 440/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Shashank Ojha
Section 142(1)Section 147Section 148Section 153CSection 271(1)(c)Section 69A

No.1092/PUN/2025, A.Y. 2013-14 : 15. Since we have already quashed the quantum assessment order which formed the very basis for levy of penalty u/s 271(1)(c) of the Act, the above penalty does not survive. Consequently, the penalty u/s 271(1)(c) of the Act is hereby deleted. Accordingly ... appeal in ITA No.1092/PUN/2025 for A.Y. 2013-14 involving the issue of penalty u/s 271(1)(c) of the Act is allowed. ITA Nos.1089 & 1093/PUN/2025, A.Ys. 2015-16 & 2016-17: 16. Since the facts and issues involved in the appeal of the assessee for the assessment year