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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)

Assistant Commissioner of Income Tax, Chandrapur Circle, Chandrapur vs. M/S Chandrapur District Central Co-Oprative Bank Limted, Chandrapur

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

ITA 241/NAG/2018[2013-14]Status: DisposedITAT Nagpur21 Aug 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

respect of provision for bad and doubtful debts which amounts furnishing of inaccurate particulars of income. The assessee is therefore, liable for penalty u/s 271(1)(c) for furnishing of inaccurate particulars of income to the tune of Rs. 39,07,11,248/- by making a wrong claim of deduction ... default within the meaning of section 271(1)(c) of the I.T. Act. Thus, it is a fit case for levy of penalty u/s 271(1)(c) of the I.T. Act.” 6. In view of the above, the Assessing Officer levied penalty under section 271(1)(c

Amit Khemka, Kolkata vs. ITO, Ward - 43(1), Kolkata

In the result, the appeal is partly allowed

ITA 636/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Aug 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

For Appellant: Shri Vikash Kumar Agarwal, FCAFor Respondent: Shri Manoj Kumar Pati, Addl. CIT, Sr. DR
Section 147Section 250Section 271BSection 68

alleging the assessee to have concealed income. This all substantiates that the assessing officer had not applied his mind while imposing the penalty u/s 271(1)(c) which is also evident from his actions that while calculating the penalty amount, the assessing officer also considered the interest component while Amit

Amit Khemka, Kolkata vs. ITO, Ward - 43(1), Kolkata

In the result, the appeal is partly allowed

ITA 635/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Aug 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

For Appellant: Shri Vikash Kumar Agarwal, FCAFor Respondent: Shri Manoj Kumar Pati, Addl. CIT, Sr. DR
Section 147Section 250Section 271BSection 68

alleging the assessee to have concealed income. This all substantiates that the assessing officer had not applied his mind while imposing the penalty u/s 271(1)(c) which is also evident from his actions that while calculating the penalty amount, the assessing officer also considered the interest component while Amit

Jamna Devi Sharma, Jaipur vs. ITO Ward 7(2), Jaipur

In the result, both the appeals of the assessee are allowed with no orders as to costs

ITA 540/JPR/2023[2007-08]Status: DisposedITAT Jaipur20 Aug 2024AY 2007-08

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rohan Sogani, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 271(1)(c)

/NFAC. 2. In the facts and circumstances of the case and in law the Id. AO has erred in imposing penalty u/s 271(1)(c) without specifically pointing out specifically limb of the section. The action of the Id. AO is illegal, unjustified, arbitrary and against the facts ... /NFAC. 2. In the facts and circumstances of the case and in law the Id. AO has erred in imposing penalty u/s 271(1)(c) without specifically pointing out specifically limb of the section. The action of the Id. AO is illegal, unjustified, arbitrary and against the facts

M/S. Manish Metal, Mumbai vs. Incometax Officer Ward 19(2)(3), Mumbai

In the result, appeals of the assessee are allowed

ITA 3289/MUM/2024[2011-12]Status: DisposedITAT Mumbai20 Aug 2024AY 2011-12

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Revenue byFor Respondent: Smt. Mahita Nair, Sr. D/R
Section 271(1)(c)

Since the issues are common in the captioned appeals and the underlying facts resulting into the levy of penalty u/s 271(1)(c) of the Act are common, therefore, these appeals were heard together and are disposed off by this common order for the sake of convenience and brevity. I.T.A ... Considering the facts in light of the judicial decisions discussed hereinabove, we do not find any merit in the levy of impugned penalty u/s 271(1)(c) of the Act. We accordingly direct the AO to delete the penalty from each assessment year in appeal. 7. In the result, appeals

M/S. Manish Metal, Mumbai vs. Income Tax Officer Ward 19(2)(3), Mumbai

In the result, appeals of the assessee are allowed

ITA 3288/MUM/2024[2010-11]Status: DisposedITAT Mumbai20 Aug 2024AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Revenue byFor Respondent: Smt. Mahita Nair, Sr. D/R
Section 271(1)(c)

Since the issues are common in the captioned appeals and the underlying facts resulting into the levy of penalty u/s 271(1)(c) of the Act are common, therefore, these appeals were heard together and are disposed off by this common order for the sake of convenience and brevity. I.T.A ... Considering the facts in light of the judicial decisions discussed hereinabove, we do not find any merit in the levy of impugned penalty u/s 271(1)(c) of the Act. We accordingly direct the AO to delete the penalty from each assessment year in appeal. 7. In the result, appeals

M/S. Manish Metal, Mumbai vs. ITO Ward 19(2)(3), Mumbai

In the result, appeals of the assessee are allowed

ITA 3287/MUM/2024[2009-10]Status: DisposedITAT Mumbai20 Aug 2024AY 2009-10

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Ble

For Appellant: Revenue byFor Respondent: Smt. Mahita Nair, Sr. D/R
Section 271(1)(c)

Since the issues are common in the captioned appeals and the underlying facts resulting into the levy of penalty u/s 271(1)(c) of the Act are common, therefore, these appeals were heard together and are disposed off by this common order for the sake of convenience and brevity. I.T.A ... Considering the facts in light of the judicial decisions discussed hereinabove, we do not find any merit in the levy of impugned penalty u/s 271(1)(c) of the Act. We accordingly direct the AO to delete the penalty from each assessment year in appeal. 7. In the result, appeals

Mohd. Imtiyaz Faqir Mohd Shaikh, Mumbai vs. Income Tax Office 23(2)(3), Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is dismissed

ITA 4020/MUM/2023[2014-15]Status: DisposedITAT Mumbai19 Aug 2024AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2014-15 Mohd. Imtiyaz Faqir Mohd Shaikh, Ito Ward 23(2)(3), 100, Blue Flame Apartment, 40 S V Room No. 115, 1St Floor, Road, Bandra (West), Vs. Matru Mandir, Tardeo, Mumbai-400050. Mumbai-400007. Pan No. Agpps 6863 A Appellant Respondent

For Appellant: Mr. Jayant BhattFor Respondent: 08/08/2024
Section 271(1)(c)Section 50CSection 56(2)(vii)Section 69C

stated, facts of the case are that the Assessing Officer Briefly stated, facts of the case are that the Assessing Officer levied penalty u/s 271(1)(c) of the Income levied penalty u/s 271(1)(c) of the Income-tax Act, 1961 (in short tax Act, 1961 (in short

Parshv Housing, Bhopal vs. ITO NFAC, Delhi

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

ITA 280/IND/2024[2015-16]Status: DisposedITAT Indore12 Aug 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniparshv Housing Ito, Nfac S 16 Gurukripa Plaza Zone Ii Delhi Mp Nagar Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aapfp1746B Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.08.2024 Date Of Pronouncement 12.08.2024

Section 147Section 271(1)(c)

aside and the matter is remanded to the record of the AO for re-adjudication of levy of penalty u/s 271(1)(c) after considering outcome of the quantum appeal pending before the CIT(A). 5. In the result, the appeal of the assessee is allowed for statistical purposes. Order

Swaminarayan Co.Op.Bank Ltd., Baroda vs. The ACIT, Circle-3(1), Baroda

In the result, the appeal of the Assessee is allowed

ITA 1411/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad09 Aug 2024AY 2010-11

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1411/Ahd/2019 "नधा"रण वष" /Assessment Year : 2010-11 Swaminarayan Co-Op. Bank Ltd. The Acit बना 1, Ashok Chambers Circle-3(1) Opp. Pathak Gate Police Station Ahmedabad म/ Madanzampa Road V/S. Vadodara 390 001 (Gujarat) "थायी लेखा सं./Pan: Aaaas 1932 N अपीलाथ"/ (Appellant) …… "" यथ"/ (Respondent) Assessee By : Shri Ashish Kanabar, Ar Revenue By : Shri Ashok Natha Bhalekar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 07/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 9/08/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 08/07/2019 Passed By The Commissioner Of Income-Tax (Appeals)-3, Vadodara [Hereinafter Referred To As “The Ld.Cit(A)” In Short] Arising Out Of The Penalty Order Dated 27/02/2019 Passed By The Assessing Officer (Ao) Under Section 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Relevant To The Assessment Year (Ay) 2010-11. Swaminarayan Co-Op. Bank Ltd. Vs. Acit Asst. Year : 2010-11

For Appellant: Shri Ashish Kanabar, ARFor Respondent: Shri Ashok Natha Bhalekar, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 271Section 271(1)(c)Section 274Section 35A

assessee has made certain claims, which were not accepted or were not acceptable to the revenue, that itself does not attract the penalty u/s 271(1)(c). 2. No penalty under section 271(1)(c) can be levied when all necessary facts were disclosed and there is no concealment

M/S. Oceanic Infrastructure Park Pvt. Ltd., Chennai vs. ITO, Circle-1, Chennai

In the result, the appeal is allowed

ITA 1629/CHNY/2024[2016-17]Status: DisposedITAT Chennai09 Aug 2024AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1629/Chny/2024 िनधा"रण वष" /Assessment Years: 2016-17

For Appellant: Shri R.Viswanathan, C.A
Section 143(3)Section 250Section 271(1)Section 271(1)(c)Section 37(1)

passed by the NFAC, Delhi. :- 2 -: 2.0 The assesse has raised grounds of appeal including additional ground of appeal contesting imposition of penalty u/s 271(1)(c) of the Act. All the grounds of appeal are on the single issue of imposition of penalty and hence adjudicated together. 3.0 Brief ... addition was unwarranted. Assesse’s appeal before the first appellate authority was answered in the negative. The Ld.AO proceeded to levy penalty u/s 271(1)(c), inter-alia, holding that the assesse has not provided him satisfactory details to defend its case. 4.0 Before us Ld.Councel for the assesse argued

Janaki Ammal Ayya Nadar Trust, Sivakasi vs. ITO, NFAC, Delhi

The appeals stand allowed for statistical purposes

ITA 505/CHNY/2024[2016-17]Status: DisposedITAT Chennai08 Aug 2024AY 2016-17

Bench: HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: NoneFor Respondent: Smt. Samantha Mullamudi, (Addl.CIT) -Ld. Sr.DR
Section 11Section 271(1)(c)

/Date of Pronouncement : 08-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of penalty u/s 271(1)(c) for captioned Assessment Years, the assessee is in further appeal before us. The registry has noted minor delay of 8 to 10 days ... seen that the assessee claimed deduction u/s 11 & 12 which was denied to the assessee. The same was confirmed by Tribunal. Consequently, penalty u/s 271(1)(c) were initiated against the assessee. The assessee submitted that rejection of claim would not amount to concealment of income. Rejecting the same

Janaki Ammal Ayya Nadar Trust, Sivakasi vs. ITO, NFAC, Delhi

The appeals stand allowed for statistical purposes

ITA 504/CHNY/2024[2015-16]Status: DisposedITAT Chennai08 Aug 2024AY 2015-16

Bench: HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: NoneFor Respondent: Smt. Samantha Mullamudi, (Addl.CIT) -Ld. Sr.DR
Section 11Section 271(1)(c)

/Date of Pronouncement : 08-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of penalty u/s 271(1)(c) for captioned Assessment Years, the assessee is in further appeal before us. The registry has noted minor delay of 8 to 10 days ... seen that the assessee claimed deduction u/s 11 & 12 which was denied to the assessee. The same was confirmed by Tribunal. Consequently, penalty u/s 271(1)(c) were initiated against the assessee. The assessee submitted that rejection of claim would not amount to concealment of income. Rejecting the same

Janaki Ammal Ayya Nadar Trust, Sivakasi vs. ITO, NFAC, Delhi

The appeals stand allowed for statistical purposes

ITA 503/CHNY/2024[2014-15]Status: DisposedITAT Chennai08 Aug 2024AY 2014-15

Bench: HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: NoneFor Respondent: Smt. Samantha Mullamudi, (Addl.CIT) -Ld. Sr.DR
Section 11Section 271(1)(c)

/Date of Pronouncement : 08-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of penalty u/s 271(1)(c) for captioned Assessment Years, the assessee is in further appeal before us. The registry has noted minor delay of 8 to 10 days ... seen that the assessee claimed deduction u/s 11 & 12 which was denied to the assessee. The same was confirmed by Tribunal. Consequently, penalty u/s 271(1)(c) were initiated against the assessee. The assessee submitted that rejection of claim would not amount to concealment of income. Rejecting the same

Janaki Ammal Ayya Nadar Trust, Sivakasi vs. ITO, NFAC, Delhi

The appeals stand allowed for statistical purposes

ITA 502/CHNY/2024[2011-12]Status: DisposedITAT Chennai08 Aug 2024AY 2011-12

Bench: HON’BLE SHRI MAHAVIR SINGH, VP AND HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: NoneFor Respondent: Smt. Samantha Mullamudi, (Addl.CIT) -Ld. Sr.DR
Section 11Section 271(1)(c)

/Date of Pronouncement : 08-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of penalty u/s 271(1)(c) for captioned Assessment Years, the assessee is in further appeal before us. The registry has noted minor delay of 8 to 10 days ... seen that the assessee claimed deduction u/s 11 & 12 which was denied to the assessee. The same was confirmed by Tribunal. Consequently, penalty u/s 271(1)(c) were initiated against the assessee. The assessee submitted that rejection of claim would not amount to concealment of income. Rejecting the same

Babu Lal Agarwal, Jaipur vs. ITO Ward 5(1), Jaipur

Appeal are dismissed

ITA 356/JPR/2024[2011-12]Status: DisposedITAT Jaipur08 Aug 2024AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Vinod Kumar Gupta, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 271(1)Section 271(1)(c)Section 50C(1)

Income tax Act 1961. In view of above. I am satisfied that it is a fit case for levy of penalty u/s 271(1)(c) of the IT Act, 1961. The quantum of penalty levy in the present case is computed as under-:- S.N. Particulars Amount (In Rs.)1. 1

DCIT, Central Circle - 7(1), Mumbai vs. Maneesh Pharmaceuticals Limited, Mumbai

In the result, appeal of the revenue is dismissed

ITA 964/MUM/2024[2010-11]Status: DisposedITAT Mumbai08 Aug 2024AY 2010-11

Bench: Ms. Kavitha Rajagopal & Shri Girish Agrawalassessment Year: 2010-11 Deputy Commissioner Of Income Maneesh Pharmaceuticals Ltd., Tax, Vs. 29-33, Ancillary Industrial Central Circle – 7(1), Plots, Near M Ward, Mumbai Govandi, Mumbai – 400 043 (Pan : Aaacm3635Q) (Appellant) (Respondent) Present For: Assessee : Shri Jaypraksh Bairagra, Ca Revenue : Smt. Sanyogita Nagpal, Cit, Dr

For Appellant: Shri Jaypraksh Bairagra, CAFor Respondent: Smt. Sanyogita Nagpal, CIT, DR
Section 10BSection 132(1)Section 143(3)Section 271(1)Section 271(1)(c)Section 274

1. On the facts and in the circumstances of the case and in law, the Ld CIT(A) erred in deleting the penalty u/s 271(1)(c) on the ground that no penalty u/s. 271(1)(c) of the Act is leviable in respect of the excess deduction u/s ... facts and in the circumstances of the case and in law, the Ld CIT(A) erred in deleting the penalty u/s 271(1)(c) on the ground that the alleged excess claim of deduction u/s. 10B of the Act made by the assessee has had no impact

Sarat Gopal Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 635/HYD/2022[2015-16]Status: DisposedITAT Hyderabad07 Aug 2024AY 2015-16

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.635/Hyd/2022 & Sa No.49/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Sarat Gopal Boppana Vs. Asstt. C. I. T. Hyderabad Central Circle 2(3) Pan:Afcpb8083K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 19/06/2024 घोषणा की तारीख/Pronouncement: 07/08/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 131Section 132Section 139(1)Section 143(3)Section 153ASection 271(1)(c)Section 274

additional income declared by the assessee fall under deemed concealment and thus, opined that it is a fit case for levy of penalty u/s 271(1)(c) of the I.T. Act, 1961. Thus, rejected the explanation of the assessee and levied penalty of Rs.62,08,225/- being 100% tax sought ... return filed u/s 153A of the I.T. Act, 1961 is to be considered as return filed u/s 139 for the purpose of penalty u/s 271(1)(c) of the Act and as per the said return, if the assessed income and the returned income is one and the same

Nova Promoters and Finlease Pvt. Ltd., Delhi vs. ITO, New Delhi

ITA 3173/DEL/2014[2000-01]Status: DisposedITAT Delhi06 Aug 2024AY 2000-01

Bench: Shri S.Rifaur Rahman & Ms.Madhumita Roynova Promoters & Vs. Ito, Ward 13(3) Finlease Pvt. Ltd. Ito Building, I.P. Estate 7, Kapil Vihar, Pitampura, Delhi – 34

For Appellant: NoneFor Respondent: Shri Anshul
Section 147Section 271(1)(c)Section 68

assessee has concealed his income or furnished inaccurate particulars of his income as such it is a fit case for imposing a penalty u/s 271(1)(c) of the IT Act, 1961. It was submitted that when penalty is initiated, the AO should be definite while issuing the notice whether ... that mentioning of the words "penalty proceedings initiated separately in assessment order is sufficient for invoking penalty action. 4.7 While imposing the penalty u/s 271(1)(c) of Rs. 46,85,932/- the AO has recorded that it is beyond doubt that the assessee has concealed his income or furnished

Chandigarh Housing Board, Chandigarh vs. Pr.CIT-1, Chandigarh

In the result, the Appeal of assessee is partly allowed

ITA 44/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh31 Jul 2024AY 2015-16

Bench: SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER ANDSHRI PARESH M. JOSHI (Judicial Member)

For Appellant: Shri A.K.Jindal, CA &For Respondent: Shri Rohit Sharma, CIT DR
Section 253Section 271(1)(c)

103/CHD/2019 ITA 125/CHD/2019 ITA 44/CHD/2021 3 3. The core issue before the ld. CIT(A) and before us is the imposition of penalty u/s 271(1)(c)of the Act. The order of Ld. AO is dated 29/06/2017 wherein a penalty of Rs. 8,51,34,922/- is imposed u/s ... same therefore the assessee could not be charged with having concealed or furnished any inaccurate particulars of income so as to levy penalty u/s 271(1)(c) of the Act." 18.4 Considering that Honourable ITAT in Para 25 has clearly held that amicable settlement arrived was issue specific