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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)

Swaran Nadhan Salaria, Mumbai vs. DCIT Central Circle 1(2), Mumbai

In the result all In the result all appeals of the assesses from AY 2014

ITA 1053/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jul 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

expenses on estimate and 10 percentile of administrative expenses on estimate and 10 percentile of administrative expenses on estimate basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s ... Assessing Officer issued show cause notice on 03.11.20222 as why Assessing Officer issued show cause notice on 03.11.20222 as why the penalty u/s 271(1)(c) of the Act might not be levied for the penalty u/s 271(1)(c) of the Act might not be levied for the penalty

Swaran Nadhan Salaria, Mumbai vs. Dict Central Circle 1(2), Mumbai

In the result all In the result all appeals of the assesses from AY 2014

ITA 1052/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

expenses on estimate and 10 percentile of administrative expenses on estimate and 10 percentile of administrative expenses on estimate basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s ... Assessing Officer issued show cause notice on 03.11.20222 as why Assessing Officer issued show cause notice on 03.11.20222 as why the penalty u/s 271(1)(c) of the Act might not be levied for the penalty u/s 271(1)(c) of the Act might not be levied for the penalty

Swaran Nadhan Salaria, Mumbai vs. DCIT Central Circle 1(2), Mumbai

In the result all In the result all appeals of the assesses from AY 2014

ITA 1051/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jul 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Virabhadra S. Mahajan, Sr. DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 153ASection 37(1)

expenses on estimate and 10 percentile of administrative expenses on estimate and 10 percentile of administrative expenses on estimate basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s 271(1)(c) of the Act for furnishing basis and initiated penalty u/s ... Assessing Officer issued show cause notice on 03.11.20222 as why Assessing Officer issued show cause notice on 03.11.20222 as why the penalty u/s 271(1)(c) of the Act might not be levied for the penalty u/s 271(1)(c) of the Act might not be levied for the penalty

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1050/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(1)

rate of 4 percentile of ‘salary and wages' expenses and 10 percentile of administrative expenses on estimate basis and initiated penalty u/s 271(1)(c) of the Act for furnishing inaccurate particulars of the income. 4.3 Further, the Assessing Officer also observed that assessee used 'shell entities' for rotation ... against the addition/disallowance made by the AO, the Assessing Officer issued show cause notice on 03.11.20222 as why the penalty u/s 271(1)(c) of the Act might not be levied for furnishing inaccurate particulars of the income. 4.5 With regard to the disallowance of “salary and wages expenses "amounting

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1049/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(1)

rate of 4 percentile of ‘salary and wages' expenses and 10 percentile of administrative expenses on estimate basis and initiated penalty u/s 271(1)(c) of the Act for furnishing inaccurate particulars of the income. 4.3 Further, the Assessing Officer also observed that assessee used 'shell entities' for rotation ... against the addition/disallowance made by the AO, the Assessing Officer issued show cause notice on 03.11.20222 as why the penalty u/s 271(1)(c) of the Act might not be levied for furnishing inaccurate particulars of the income. 4.5 With regard to the disallowance of “salary and wages expenses " amounting

Liberty Marketing Co, Delhi vs. ITO, Income Tax Department

In the result, the appeal of the assessee is allowed

ITA 233/DEL/2025[2008-09]Status: DisposedITAT Delhi30 Jul 2025AY 2008-09

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Liberty Marketing Co. Vs. Ito, B-12, Gulmohar Park, Ward-29(1), Delhi (Appellant) (Respondent) Pan:Aaafl2142E

For Appellant: Shri Mohit Bhardwaj, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 144Section 271(1)(c)

issue to be decided in this appeal is as to whether the ld CIT(A) was justified in confirming the levy of penalty u/s 271(1)(c) of the Act in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused the material

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 488/PAT/2022[2016-17]Status: DisposedITAT Patna29 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

raised the following issues:- (1) For that the Ld. CIT(A) has erred in affirming penalty u/s 271(1)(c) on the difference between income assessed and relief allowed by Ld. CIT(A) by treating the same to be concealed income. (2) For that the Ld. CIT(A) has erred ... erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases of estimation of net/gross profit and mere sustenance of addition by CIT(A) and its acceptance

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 487/PAT/2022[2015-16]Status: DisposedITAT Patna29 Jul 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

raised the following issues:- (1) For that the Ld. CIT(A) has erred in affirming penalty u/s 271(1)(c) on the difference between income assessed and relief allowed by Ld. CIT(A) by treating the same to be concealed income. (2) For that the Ld. CIT(A) has erred ... erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases of estimation of net/gross profit and mere sustenance of addition by CIT(A) and its acceptance

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 486/PAT/2022[2014-15]Status: DisposedITAT Patna29 Jul 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

raised the following issues:- (1) For that the Ld. CIT(A) has erred in affirming penalty u/s 271(1)(c) on the difference between income assessed and relief allowed by Ld. CIT(A) by treating the same to be concealed income. (2) For that the Ld. CIT(A) has erred ... erred in not considering the judicial precedents relied upon by the appellant in its written submission wherein it has categorically held that penalty u/s 271(1)(c) is not sustainable in cases of estimation of net/gross profit and mere sustenance of addition by CIT(A) and its acceptance

Aspee Sons, Solan vs. Income Tax Officer, Parwanoo

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

ITA 1167/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh29 Jul 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 271(1)(c)Section 80Section 80I

circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of imposition of penalty u/s 271(1)(c) of Rs. 5,66,616/- in respect of denial of deduction u/s 80IC on interest income. 3. That on facts, circumstances and legal ... position of the case, Worthy CIT(A) has erred in confirming the action of Ld. AO of imposition of penalty u/s 271(1)(c) of Rs. 5,66,616/ on account of receipt alleged to be not directly derived from manufacturing activities of the industrial undertaking and allegedly wrongly declared

Shivratan Motilal Rathi HUF, Pune vs. ITO, Jalna

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

ITA 606/PUN/2025[2011-12]Status: DisposedITAT Pune29 Jul 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

were issued but the assessee did not comply with any of the notices consequently the Assessing Officer vide order dated 27.08.2015 imposed penalty u/s 271(1)(c) of the IT Act of Rs.13,42,440/-. 7. Against the above ex-parte penalty order, the assessee HUF preferred appeal before ... aside the impugned order passed by Ld. CIT(A)/NFAC in the penalty appeal. Accordingly, the impugned matter involving the issue of penalty u/s 271(1)(c) of the IT Act is also remanded back to the file of Ld. CIT(A)/NFAC with a direction to adjudicate the penalty

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

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

ITA 605/PUN/2025[2008-2009]Status: DisposedITAT Pune29 Jul 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

were issued but the assessee did not comply with any of the notices consequently the Assessing Officer vide order dated 27.08.2015 imposed penalty u/s 271(1)(c) of the IT Act of Rs.13,42,440/-. 7. Against the above ex-parte penalty order, the assessee HUF preferred appeal before ... aside the impugned order passed by Ld. CIT(A)/NFAC in the penalty appeal. Accordingly, the impugned matter involving the issue of penalty u/s 271(1)(c) of the IT Act is also remanded back to the file of Ld. CIT(A)/NFAC with a direction to adjudicate the penalty

Baidya Nath Dey, Burdwan vs. ITO, Ward 1(3), Durgapur

In the result, the appeal of the assessee is allowed

ITA 337/KOL/2025[2011-12]Status: DisposedITAT Kolkata29 Jul 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 1(3), Durgapur, Baidya Nath Dey Aaykar Bhavan, Aykar Bithi, City Station More, P.O. Ukhra Centre, Durgapur, Vs. Burdwan-713363, West Bengal West Bengal-713216 (Appellant) (Respondent) Pan No. Ahppd0247E Assessee By : Shri Shuvo Chackrborty, Ar Revenue By : Shri Manoj Kumar Pati, Dr Date Of Hearing: 17.07.2025 Date Of Pronouncement: 29.07.2025

For Appellant: Shri Shuvo Chackrborty, ARFor Respondent: Shri Manoj Kumar Pati, DR
Section 143(3)Section 271Section 271(1)(c)Section 274

c) of the Act dated 14.12.2018 initiating the penalty Baidya Nath Dey; A.Y. 2011-12 proceedings. Finally, the ld. AO imposed the penalty u/s 271(1)(c) of the Act, being 100% of the tax to be evaded amounting to ₹7,38,000/-, which was affirmed

Oriental Relays LLP (Successor to Oriental Relays Pvt. Ltd.), Kolkata vs. A.C.I.T., Circle - 8(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1574/KOL/2024[2016-2017]Status: DisposedITAT Kolkata29 Jul 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Oriental Relays Llp Pan No. Aahfo5108L Acit, Circle 8(2), (Successor To Oriental Relays Aaykar Bhavan, P7, Pvt. Ltd Pan No. Aaaco3456H) Chowringhee Square, Vs. 2Nd Floor, S.B. Tower, 37 Kolkata-700069, West Bengal Shakespeare Sarani, Kolkata-700017, West Bengal (Respondent) (Appellant)

For Appellant: Shri Shreya Loyalka, ARFor Respondent: Shri Manoj Kumar Pati, DR
Section 143(3)Section 271Section 271(1)(c)Section 274

accordingly, addition was partly sustained to the extent of ₹84,70,915/-. The ld. AO imposed the penalty u/s 271(1)(c) of the Act, being 100% of the tax to be evaded amounting to ₹18,67,159/-, which was affirmed by the ld. CIT (A). 04. Now, the assessee

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 894/CHNY/2025[2016-17]Status: DisposedITAT Chennai29 Jul 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 893/CHNY/2025[2015-16]Status: DisposedITAT Chennai29 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 892/CHNY/2025[2014-15]Status: DisposedITAT Chennai29 Jul 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 891/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 Jul 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA

M/S.Redington Distributors Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 890/CHNY/2025[2012-13]Status: DisposedITAT Chennai29 Jul 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA

M/S.Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 889/CHNY/2025[2011-12]Status: DisposedITAT Chennai29 Jul 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

Rs.17,61,12,836/- made in AY 2011-12 to Rs. 2,18,18,978/-. 9. The AO thereafter initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution on the premise that the assessee did not offer the said income ... income if any filed by the appellant and hence not disclosed to the AO. Thus the AO was right in initiating penalty u/s 271(1)(c) for furnishing inaccurate particulars in the facts and circumstances of the case. There is no bar as per the DTAA