← All Phrases

“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)

DCIT Circle-10(1), New Delhi vs. Htc India Pvt Ltd, Gurgaon

In the result, the appeal of the Revenue is dismissed

ITA 1785/DEL/2020[2011-12]Status: DisposedITAT Delhi30 May 2024AY 2011-12

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Vivek Kr. Upadhyay, Sr. DR
Section 271(1)Section 271(1)(c)Section 92BSection 92C

Rs.2.46 Cr. and consequently penalty has been levied u/s 271(1)(c). 6. To put it straight, penalty u/s 271(1)(c) has been levied on the amount of adjustment made u/s 92CA. Hence, the question before us is “whether the penalty levied u/s 271(1)(c) on the adjustment ... derived by it and, in any case, it amounted to duplication of services. Under such circumstances, a question arises as to whether penalty u/s 271(1)(c) can be imposed. In this regard, we find that the relevant provision is Explanation 7 to section 271(1), which reads as under

Assistant Commissioner of Income Tax, Non Corporate Circle-10, Chennai vs. Sj Suryah, Chennai

In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed

ITA 594/CHNY/2024[2002-03]Status: DisposedITAT Chennai29 May 2024AY 2002-03

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri P. Sajit Kumar, JCIT
Section 153ASection 271Section 271(1)(c)Section 274

without striking down the inapplicable portion in the printed notice, the assessee was not aware of which charge/fault the AO proposed penalty u/s 271(1)(c) of the Act, therefore the impugned notices are bad in law and therefore the penalty levied need to be deleted. 5. Per contra

Shri.S.J.Suryah, Chennai, Tamil Nadu vs. Assistant Commissioner of Income Tax, Central Circle 2(4), Chennai

In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed

ITA 806/CHNY/2023[2002-03]Status: DisposedITAT Chennai29 May 2024AY 2002-03

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri P. Sajit Kumar, JCIT
Section 153ASection 271Section 271(1)(c)Section 274

without striking down the inapplicable portion in the printed notice, the assessee was not aware of which charge/fault the AO proposed penalty u/s 271(1)(c) of the Act, therefore the impugned notices are bad in law and therefore the penalty levied need to be deleted. 5. Per contra

Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore vs. Mitsubishi Heavy Industries-Vst Diesel Engines Private Limited, Mysuru

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

ITA 505/BANG/2024[2016-17]Status: DisposedITAT Bangalore29 May 2024AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Shri Ankith, CA
Section 139Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)

resolution by assessee suo-moto amounts to furnishing inaccurate particulars of income.” 4. The facts that lead to levy of penalty U/s 271(1)(c) of the Income Tax Act, 1961 are stated in brief as under:- 4.1 The brief facts of the case are that the Appellant Company ... about the additional taxes paid by the Assessee on 30.05.2018. The income was assessed at Rs.10,12,55,130/ and accordingly the penalty u/s. 271(1)(c) was initiated on 17.12.2018 for furnishing inaccurate particulars of income. Page 5 of 19 4.7 The assessee also filed for rectification u/s

ACIT-19(3), Mumbai vs. Vinod Hirachand Sanghvi, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4870/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 May 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

Tribunal. 6. At the time of hearing the Ld. AR submitted that the CIT(A) erred in partly sustaining the penalty u/s 271(1)(c) of the Act. The Hon’ble tribunal has directed the Assessing officer to restrict the addition on account of bogus purchases estimating @8% of bogus ... perused the material on record. The sole crux of the disputed issue as envisaged by the Ld. AR that levy of penalty u/s 271(1)(c) 6 ITA. No. 4473, 4472, 4470 & 4870/MUM/2023. Vinod Hirachand Sanghvi, Mumbai. of the Act by the A.O based on the assessment order under section

Income Tax Officer Ward-3(1), Kalyan vs. Geeta Khare, Dombivli West

In the result, both the appeals of the assessee are allowed

ITA 4520/MUM/2023[2014-15]Status: DisposedITAT Mumbai29 May 2024AY 2014-15

Bench: the Hon'ble High Court of Bombay. The appellant craves to leave add, amend or alter or alter any ground/grounds which may be necessary." 3. The brief facts of the case is that the assessment was completed under section 143(3) and addition was made related to sale of shares for claiming Long Term Capital Gain amounting to Rs.2,26,36,372/-. The addition was confirmed as concealed income amount to Rs.2,26,36,372/-. The penalty was levied at 100% of the tax sought to be evaded which amount to R

For Appellant: Shri Nilkanth Khandelwal - AdvocateFor Respondent: Ms. Sujatha Iyangar SR. AR
Section 10(38)Section 143(3)Section 250Section 271(1)(c)Section 69

appeal: - “1. On the facts and in the circumstances of the case and in law, the CIT(A) erred in deleting penalty u/s 271(1)(c) without appreciating the fact that the appeal of the Revenue on the quantum assessmentorder is pending before the Hon’ble High Court of Bombay

Vinod Hirachand Sanghvi, Mumbai vs. DCIT 15(2), Piramal Chambers, Lalbaug, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4473/MUM/2023[2009-10]Status: DisposedITAT Mumbai29 May 2024AY 2009-10

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

Tribunal. 6. At the time of hearing the Ld. AR submitted that the CIT(A) erred in partly sustaining the penalty u/s 271(1)(c) of the Act. The Hon’ble tribunal has directed the Assessing officer to restrict the addition on account of bogus purchases estimating @8% of bogus ... perused the material on record. The sole crux of the disputed issue as envisaged by the Ld. AR that levy of penalty u/s 271(1)(c) 6 ITA. No. 4473, 4472, 4470 & 4870/MUM/2023. Vinod Hirachand Sanghvi, Mumbai. of the Act by the A.O based on the assessment order under section

Vinod Hirachand Sanghvi, Mumbai vs. ACIT-15(2), Piramal Chambers, Lalbaug, Parel, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4472/MUM/2023[2010-11]Status: DisposedITAT Mumbai29 May 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

Tribunal. 6. At the time of hearing the Ld. AR submitted that the CIT(A) erred in partly sustaining the penalty u/s 271(1)(c) of the Act. The Hon’ble tribunal has directed the Assessing officer to restrict the addition on account of bogus purchases estimating @8% of bogus ... perused the material on record. The sole crux of the disputed issue as envisaged by the Ld. AR that levy of penalty u/s 271(1)(c) 6 ITA. No. 4473, 4472, 4470 & 4870/MUM/2023. Vinod Hirachand Sanghvi, Mumbai. of the Act by the A.O based on the assessment order under section

Vinod Hirachand Sanghvi, Mumbai vs. ACIT-19(3), Piramal Chambers, Lalbaug, Parel, Mumbai

In the result, the appeals filed by the assessee for the A

ITA 4470/MUM/2023[2011-12]Status: DisposedITAT Mumbai29 May 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos 4473, 4472 & 4470/Mum/2023 (A.Y.2009-10, 2010-11 & 2011-12)

Section 271(1)(c)

Tribunal. 6. At the time of hearing the Ld. AR submitted that the CIT(A) erred in partly sustaining the penalty u/s 271(1)(c) of the Act. The Hon’ble tribunal has directed the Assessing officer to restrict the addition on account of bogus purchases estimating @8% of bogus ... perused the material on record. The sole crux of the disputed issue as envisaged by the Ld. AR that levy of penalty u/s 271(1)(c) 6 ITA. No. 4473, 4472, 4470 & 4870/MUM/2023. Vinod Hirachand Sanghvi, Mumbai. of the Act by the A.O based on the assessment order under section

The Assistant Commissioner of Income Tax, Central Circle-2, Viskahapatnam vs. Sri Vijaya Visakha Milk Producers Company Limited, Visakhapatnam

In the result, appeals filed by the revenue and the cross objections filed by the assessee are dismissed for the A

ITA 239/VIZ/2020[2012-13]Status: DisposedITAT Visakhapatnam28 May 2024AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.239/Viz/2020 & 237/Viz/2020 (ननधधारण वर्ा/ Assessment Year : 2012-13 &2013-14) Assistant Commissioner Of Vs. M/S Sri Vijaya Visakha Milk Income Tax Producers Company Limited Central Circle-2 Visakha Diary, Bhpv Post Visakhapatnam Nh-5, Nathayyapalem Visakhapatnam [Pan :Aajcs7398P] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR
Section 131Section 132Section 143(3)Section 271(1)(c)

Vijaya Visakha Milk Producers Co.Ltd., Visakhapatnam precedents, as detailed in his order, allowed the appeal of the assessee, thereby deleting the penalty u/s 271(1)(c) of the Act. 4. Being aggrieved by the order of the Ld.CIT(A), the revenue is in appeal before us by raising the following ... 5895/Del/2016 (xiii) S.M.J.Housing Vs.Commissioner of Income Tax (2013) 357 ITR 0698 (Mad) The Ld.AR, therefore, pleaded that penalty u/s 271(1)(c) be deleted as there is no concealment, but it is only due to voluntary disclosure by the assessee. 7. We have heard both the parties and perused

Ashok Nathmal Garodia, Mumbai vs. ITO Ward 13(1)(1), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 553/MUM/2024[2013-14]Status: DisposedITAT Mumbai28 May 2024AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: Ms Neha ParanjapeFor Respondent: Shri Mirza Azhar Beig
Section 143(3)Section 147Section 148Section 148(1)Section 250Section 271(1)(c)Section 274

u/s 148 of the Act. Accordingly, we find no infirmity in the Ashok Nathmal Garodia. impugned order in upholding the levy of penalty u/s 271(1)(c) of the Act, and therefore, the same is upheld. As a result, the grounds raised by the assessee are dismissed

Income Tax Officer-19(2)(2), Mumbai vs. Mukeshkumar Somatmalji Doshi, Mumbai

ITA 4459/MUM/2023[2009-10]Status: DisposedITAT Mumbai28 May 2024AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm Mukeshkumar Somatmalji Income Tax Officer Doshi, Ward 19(2)(2) 63/A, 1St Khumbharwada Lane, Room No.503, Bhandari Street, Vs. Piramal Chamber, Near Goel Deval, Lalgaug, Lower Parel, Mumbai-400 004 Mumbai-400 012 (Appellant) (Respondent) Pan No. Abqpd5578B

For Appellant: NoneFor Respondent: Shri Rajesh Meshram, DR
Section 133(6)Section 143(3)Section 145(3)Section 147Section 148Section 271(1)(c)

1. "Whether on the facts and Circumstances of the case and in law, the Ld. CIT (A) has erred in restricting the penalty u/s 271(1)(c) of the 1.T.Act 1961, @ 12. 5% of bogus purchases of Rs 61 ,77,214/- on alleged purchases from 5 parties/entities?" 2. "Whether ... Tyre Retreading and Rubber Industries - 2014 (2) TMI 21 - RAJASTHAN HIGH COURT , the appellate orders of the ld. CIT (A) deleting the penalty u/s 271 (1) (c) of The Act , are confirmed. 013. In view of this the order of the learned CIT (A) is confirmed and the appeal

Novartis India Ltd, Mumbai vs. Asst CIT 7(1), Mumbai

ITA 2308/MUM/2012[2003-04]Status: DisposedITAT Mumbai28 May 2024AY 2003-04

Bench: Pavan Kumar Gadale & Shri Girish Agrawal

Section 37(1)Section 41(3)Section 80H

IN THE INCOME TAX APPELLATE TRIBUNAL, “J” BENCH MUMBAI BEFORE PAVAN KUMAR GADALE, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

ACIT Cir 7(1), Mumbai vs. Novartis India ( Formelry Known As Hindustan Ciba Giegy Ltd), Mumbai

In the result, (i) the appeal filed by the assessee is partly allowed for statistical purpose (ii) the appeal filed by the revenue is dismissed and (iii) the Cross Objections filed by the assessee ...

ITA 2188/MUM/2012[2003-04]Status: DisposedITAT Mumbai28 May 2024AY 2003-04

Bench: Pavan Kumar Gadale & Shri Girish Agrawal & Co 76/Mum/2013 (A.Y 2003-04) Novartis India Limited Vs. Deputy Commissioner Of Income–Tax–14(1)(1) Inspire Bkc, 7Th Floor, Room No 432, Bandra Kurla Complex, Aaykar Bhawan, Bandra (E) M.K. Marg, Mumbai-400051. Mumbai-400020. Pan/Gir No. Aaach2914F (अपीलाथ"/Appellant) (""यथ"/Respondent) Deputy Commissioner Vs. Novartis India Limited Of Income–Tax–14(1)(1) Inspire Bkc, 7Th Floor, Room No 432, Bandra Kurla Complex, Aaykar Bhawan, Bandra (E) M.K. Marg, Mumbai-400051 Mumbai-400020 Pan/Gir No. Aaach2914F (अपीलाथ"/Appellant (""यथ"/Respondent)

Section 37(1)Section 41(3)Section 80H

property have already been claimed in the computation of income. The income of house property is therefore determined at Rs.2,887,610/-. Penalty u/s 271(1)(c) is initiated separately for furnishing inaccurate particulars of income” 18. The sixteenth disputed issue with respect to computation of income from capital gains

DCIT, Circle-3(2), New Delhi vs. Asian Consolidated Inds.Ltd), Rewari

Appeal is dismissed

ITA 3013/DEL/2018[1997-98]Status: DisposedITAT Delhi28 May 2024AY 1997-98

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singhassessment Year: 1997-98

Section 143(3)Section 144Section 264Section 271(1)(c)Section 274Section 292

penalty should have been levied on the assessee as the determination of such limb is sine qua non for imposition of penalty u/s 271(1)(c) 1. This is an appeal filed by revenue against the order dated 22.11.2017 passed by CIT(A) deleting the penalty of Rs.20 ... enclosed at PB Pg. 35. 3. However, while issuing such notice, the AO has failed to specify the limb under which the penalty u/s 271(1)(c) is being initiated i.e. whether it is for concealment of the particulars of the income or for furnishing inaccurate particulars of the income

DCIT, Circle-3(2), New Delhi vs. Asian Consolidated Inds.Ltd), Rewari

Appeal of the Revenue is dismissed

ITA 6219/DEL/2017[1998-99]Status: DisposedITAT Delhi28 May 2024AY 1998-99

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singhassessment Year: 1998-99

Section 143(3)Section 145Section 264Section 271(1)Section 271(1)(c)Section 274Section 292B

penalty should have been levied on the assessee as the determination of such limb is sine qua non for imposition of penalty u/s 271(1)(c) 1. This is an appeal filed by revenue against the order dated 22.11.2017 passed by CIT(A) deleting the penalty of Rs.2 ... enclosed at PB Pg. 37. 3. However, while issuing such notice, the AO has failed to specify the limb under which the penalty u/s 271(1)(c) is being initiated i.e. whether it is for concealment of the particulars of the income or for furnishing inaccurate particulars of the income

Iris Motel & Resorts Pvt Ltd, Faridabad vs. ACIT Circle-1, Faridabad

In the result, both the appeals of the assessee are allowed

ITA 1441/DEL/2020[2013-14]Status: DisposedITAT Delhi27 May 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M. Balaganeshiris Motel & Resorts Pvt. Ltd, Vs. Dcit, Rra Taxindia, D-28, South Circle-1, Extension, Part-1, New Delhi Faridabad (Appellant) (Respondent) Pan: Aaccl5724L Iris Motel & Resorts Pvt. Ltd, Vs. Acit, Rra Taxindia, D-28, South Circle-1, Extension, Part-1, New Delhi Faridabad (Appellant) (Respondent) Pan: Aaccl5724L Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Agarwal, Adv Revenue By: Shri Anuj Garg, Sr. Dr Date Of Hearing 28/03/2024 Date Of Pronouncement 27/05/2024

For Appellant: Dr. Rakesh gupta, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 68

appeal is decided in favour of the assessee, other appeals of the assessee in ITA No. 1441/Del/ 2020 challenging the levy of penalty u/s 271(1)(c) would have no legs to stand and penalty is here by deleted. 10. In the result, both the appeals of the assessee

Iris Motel and Resort Pvt. Ltd., Faridabad vs. DCIT, Circle- I, Faridabad

In the result, both the appeals of the assessee are allowed

ITA 533/DEL/2018[2013-14]Status: DisposedITAT Delhi27 May 2024AY 2013-14

Bench: Shri Saktijit Dey & Shri M. Balaganeshiris Motel & Resorts Pvt. Ltd, Vs. Dcit, Rra Taxindia, D-28, South Circle-1, Extension, Part-1, New Delhi Faridabad (Appellant) (Respondent) Pan: Aaccl5724L Iris Motel & Resorts Pvt. Ltd, Vs. Acit, Rra Taxindia, D-28, South Circle-1, Extension, Part-1, New Delhi Faridabad (Appellant) (Respondent) Pan: Aaccl5724L Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Agarwal, Adv Revenue By: Shri Anuj Garg, Sr. Dr Date Of Hearing 28/03/2024 Date Of Pronouncement 27/05/2024

For Appellant: Dr. Rakesh gupta, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 68

appeal is decided in favour of the assessee, other appeals of the assessee in ITA No. 1441/Del/ 2020 challenging the levy of penalty u/s 271(1)(c) would have no legs to stand and penalty is here by deleted. 10. In the result, both the appeals of the assessee

Income Tax Officer, Ward-7(3), Pune, Bodhi Tower vs. Iranna Bhujang Nadgam, Thite Vasti

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

ITA 43/PUN/2024[2018-19]Status: DisposedITAT Pune22 May 2024AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: NoneFor Respondent: Shri Keyur Patel, CIT-DR
Section 143(2)Section 144Section 271ASection 69

levied by observing as under: “6. Decision: The appellant in its ground of appeal has assailed the AO in initiating and levying penalty u/s 271(1)(c) of the Act of Rs.2,19,22,260/-. The AO initiated and levied penalty on the basis of the addition made

Income Tax Officer, Ward-7(3), Pune, Bodhi Tower vs. Iranna Bhujang Nadgam, Thite Vasti

In the result, both the appeals filed by the Revenue are allowed for statistical purposes

ITA 42/PUN/2024[2018-19]Status: DisposedITAT Pune22 May 2024AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: NoneFor Respondent: Shri Keyur Patel, CIT-DR
Section 143(2)Section 144Section 271ASection 69

levied by observing as under: “6. Decision: The appellant in its ground of appeal has assailed the AO in initiating and levying penalty u/s 271(1)(c) of the Act of Rs.2,19,22,260/-. The AO initiated and levied penalty on the basis of the addition made