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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)

South Eastern Coalfields Ltd, Bilaspur(Cg) vs. Dy.. C.I.T.-1(1), Bilaspur(Cg)

ITA 156/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

factual information given by him has not been found to be incorrect, he will not be liable to imposition of penalty u/s 271(1)(c) of the Act, even the claim made by him is unsustainable in law, provided that the either substantiated explanation offered by him or the explanation ... ALIT Vs. Khanna Annadhnam 142 TTJ 1 (Del) and it is held that penalty for furnishing such inaccurate particulars of expenses attracts penalty u/s 271(1)(c) of the Act. Similarly, regarding imposition of penalty against addition of Rs.11385.80 lakhs made by disallowing provisions for leave 14 South Eastern Coalfields

The Dy. CIT- Cir.-1(1), Bilaspur(Cg) vs. South Eastern Coalfilds Ltd., Bilaspur(Cg)

ITA 152/BIL/2014[2009-10]Status: DisposedITAT Raipur09 Jun 2023AY 2009-10

Bench: Shri Ravish Sood & Shri Arun Khodpia

Section 271(1)(c)

factual information given by him has not been found to be incorrect, he will not be liable to imposition of penalty u/s 271(1)(c) of the Act, even the claim made by him is unsustainable in law, provided that the either substantiated explanation offered by him or the explanation ... ALIT Vs. Khanna Annadhnam 142 TTJ 1 (Del) and it is held that penalty for furnishing such inaccurate particulars of expenses attracts penalty u/s 271(1)(c) of the Act. Similarly, regarding imposition of penalty against addition of Rs.11385.80 lakhs made by disallowing provisions for leave 14 South Eastern Coalfields

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1079/DEL/2022[2015-16]Status: DisposedITAT Delhi07 Jun 2023AY 2015-16

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1078/DEL/2022[2014-15]Status: DisposedITAT Delhi07 Jun 2023AY 2014-15

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1077/DEL/2022[2013-14]Status: DisposedITAT Delhi07 Jun 2023AY 2013-14

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1076/DEL/2022[2012-13]Status: DisposedITAT Delhi07 Jun 2023AY 2012-13

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1075/DEL/2022[2011-12]Status: DisposedITAT Delhi07 Jun 2023AY 2011-12

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1074/DEL/2022[2009-10]Status: DisposedITAT Delhi07 Jun 2023AY 2009-10

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Kamlesh Gupta, New Delhi vs. DCIT, CC-1, New Delhi

In the results, the appeals of the assessee are allowed

ITA 1073/DEL/2022[2010-11]Status: DisposedITAT Delhi07 Jun 2023AY 2010-11

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

For Appellant: Sh. Neeraj Jain, CAFor Respondent: Sh. Sanjay Kumar, Sr. DR
Section 271(1)(c)Section 271A

dealing with ground no. 4 raised before him contending that the Id. AO had exceeded his jurisdiction in initiating and imposing penalty u/s 271(1)(c) and in sustaining the penalty imposed by the assessing officer on account of estimated profits amounting to Rs. 1,85,924/- from alleged undisclosed ... followed the settled legal position that when income is estimated, then, there can be no question of imposing penalty u/s 271(1)(c) of the Act and has deleted the penalty imposed u/s 271(1)(c). Similar view is upheld in the judgment of ITAT, Jaipur in the case

Shri Kuldip Singh S/O Shri Parkash Singh, Saheed Bhagat Singh Nagar vs. Income Tax Officer, Nawanshahar

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

ITA 374/ASR/2019[2010-11]Status: DisposedITAT Amritsar06 Jun 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 2Section 271(1)(c)

that the order of ld. CIT(A) is infirm and perverse to the facts on the record in confirming the levy of penalty u/s 271(1)(c) of the Act. 5. In the above view, we accept the grievance of the assessee as genuine considering the peculiar facts ... case. We, therefore, quashed the impugned order and levy of such, the penalty u/s 271(1)(c) of Rs.108,150/- is deleted. 6. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court on 06.06.2023 (Anikesh Banerjee) (Dr. M. L. Meena

Murliwala Agrotech Private Limited, Rajasthan vs. DCIT Circle-14, Delhi

In the result, the appeal of the assessee is allowed

ITA 609/DEL/2022[2015-16]Status: DisposedITAT Delhi01 Jun 2023AY 2015-16

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2015-16 Murliwala Agrotech Private Limited, Vs Dcit, G-20-245, Ricco Industrial Area, Circle-14, Gudli Udaipur, Delhi. Rajasthan – 313024. Pan: Aaccm0796Q (Applicant) (Respondent) Assessee By : Shri Susheel Kumar, Ca & Ms Archana Jain, Ca Revenue By : Ms Raja Rajeshwari R. Sr. Dr Date Of Hearing : 24.05.2023 Date Of Pronouncement : 01.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.609/Del/2022 For Ay 2015-16 Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals)-26, New Delhi [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] In Appeal No.10255/19-20 Dated 10.12.2021 Against The Order U/S 271(1)(C) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 27.06.2019 Passed By The Ld. Assessing Officer, Circle-2, Udaipur (Hereinafter Referred To As ‘Ld. Ao’). 2. The Only Effective 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 & Circumstances Of The Instant Case.

For Appellant: Shri Susheel Kumar, CA &For Respondent: Ms Raja Rajeshwari R. Sr. DR
Section 271(1)(c)Section 274

effective 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

Mini Tradex Private Limited, New Delhi vs. ITO Ward - 16(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 8029/DEL/2019[2015-16]Status: DisposedITAT Delhi01 Jun 2023AY 2015-16

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2015-16 Mini Tradex Private Limited, Vs Ito, C/O Rohit Tiwari, Ward-16(4), 8024, Ats Greens Paradiso, New Delhi. Chi Iv, Noida, Uttar Pradesh – 201310. Pan: Aagcm0239E (Applicant) (Respondent) Assessee By : Ms Tanya, Advocate Revenue By : Ms Raja Rajeshwari R. Sr. Dr Date Of Hearing : 24.05.2023 Date Of Pronouncement : 01.06.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.8029/Del/2019 For Ay 2015-16 Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals)-6, Delhi [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] In Appeal No.Cit(A), Delhi-6/10103/18-19 Dated 07.05.2019 Against The Order U/S 271(1)(C) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 18.06.2018 Passed By The Ld. Assessing Officer, Ward-16(4), New Delhi (Hereinafter Referred To As ‘Ld. Ao’). 2. The Only Effective 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 & Circumstances Of The Instant Case.

For Appellant: Ms Tanya, AdvocateFor Respondent: Ms Raja Rajeshwari R. Sr. DR
Section 271(1)(c)Section 274

effective 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

Income Tax Officer-17(2)(1), Mumbai vs. Chetan Shashikant Shah, Mumbai

In the result appeal of the revenue is stand dismissed

ITA 813/MUM/2023[2009-10]Status: DisposedITAT Mumbai31 May 2023AY 2009-10

Bench: Shri Amit Shukla & Shri Amarjit Singhito-17(1)(2)(1) Vs. Chetan Shashikant Shah 1St, Floor, Room No. 104, 1St, Floor, Office No. 101, Kautilya Bhavan, G. 33, Dariyastan Street, Block, Bkc, Bandra(E) Masjid, Mumbai, Mandvi Mumbai 400051 S.O 400003 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aacps9153Q Appellant .. Respondent Appellant By : Shri. Rajesh S. Shah Respondent By : Shri. Krishna Kumar Date Of Hearing 30.05.2023 Date Of Pronouncement 31.05.2023 आदेश / O R D E R Per Amarjit Singh (Am):

For Appellant: Shri. Rajesh S. ShahFor Respondent: Shri. Krishna Kumar
Section 143(1)Section 148Section 271(1)(c)

rate of addition to 8% of gross profit as against rate of 12.5% estimated by the AO. The AO has also initiated penalty u/s 271(1)(c) of the Act. Vide order u/s 271(1)(c) of the Act dated 07.01.2022, the assessing officer has levied penalty

Thomas Cook (India) Ltd, Mumbai vs. Dy CIT 1 (3)92), Mumbai

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

ITA 7807/MUM/2019[2015-16]Status: DisposedITAT Mumbai31 May 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Thomas Cook (India) Ltd., Dy. Cit-1(3)(2), A Wing, 11Th Floor, Marathon Room No. 540, 5Th Floor, Vs. Futurex, N.M. Joshi Marg, Aayakar Bhavan, M.K. Lower Parel (East), Road, Mumbai-400013. Mumbai-400020. Pan No. Aaact 4050 C Appellant Respondent Assessee By : Mr. Ketan Ved Revenue By : Ms. Richa Gulati, Dr : Date Of Hearing 30/05/2023 : Date Of Pronouncement 31/05/2023 Order

For Appellant: Mr. Ketan VedFor Respondent: Ms. Richa Gulati, DR
Section 115Section 115JSection 14ASection 37(1)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND MS. KAVITHA

Sushila Goyal, New Delhi vs. ITO Ward 22(3), New Delhi

In the result, appeal of the assessee is allowed

ITA 3012/DEL/2019[2014-15]Status: DisposedITAT Delhi31 May 2023AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Chandra Mohan Gargsushila Goyal Vs. Ito Flat No.4, Rr Apartments Ward – 22(3), 3-4, Mangalpuri, Mehrauli New Delhi New Delhi – 110 030 Pan No. Ajspg 2559 B (Appellant) (Respondent) Assessee By Shri Ajit Gandhi, C.A. Revenue By Shri Pankaj Khanna, Sr. D.R. Date Of Hearing: 28.02.2023 Date Of Pronouncement: 31.05.2023

Section 143(3)Section 271Section 271(1)(c)

Learned AR submitted that though the assessee has raised various grounds but the sole controversy is with respect to the levying of penalty u/s 271(1)(c) of the Act. 6. Before us, Learned AR submitted that during the year under consideration, assessee had taken loans and advances from various ... rival submissions and perused the material available on record. The issue in the present ground is with respect to the levy of penalty u/s 271(1)(c) of the Act. It is an undisputed fact that during the year under consideration, assessee had taken aggregate loans and advances from various

Gtpl Rajwadi Network Pvt. Ltd., Bamroli vs. Dy. Commissioner of Income Tax, Cir-1(1)(2), Surat

In the result, appeal filed by the assessee is allowed

ITA 95/SRT/2023[2014-15]Status: DisposedITAT Surat31 May 2023AY 2014-15

Bench: SHRI PAWAN SINGH (Judicial Member), DR. A. L. SAINI (Accountant Member)

For Appellant: Shri Sapnesh R Sheth, CAFor Respondent: Shri Vinod Kumar, Sr- DR
Section 143(3)Section 271(1)Section 271(1)(c)

subject, the learned Commissioner of Income-Tax (Appeals), NFAC has erred in penalty confirming the action of Assessing Officer in imposing penalty u/s 271(1)(c) of the I.T. Act, 1961 by sustaining the penalty to the extent of Rs.1,56,587/- as against Rs.4,69,761/- imposed by Assessing

Kl Crescent Infrastructure Pvt Ltd., Navi Mumbai vs. Income Tax Officer-15(2)(1), Mumbai

Appeal is partly allowed

ITA 172/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 May 2023AY 2010-11

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blekl Crescent Infrastructure Pvt Ltd V. Ito 15(2)(1) A-390/39, Ttc Industrial Zone Aayakar Bhavan Midc, Mahape, Post Ghansoli Mumbai- 400020 Navi Mumbai- 400701 Pan: Aadck3832C (Appellant) (Respondent) Kl Crescent Infrastructure Pvt Ltd V. Acit 15(2)(2) A-390/39, Ttc Industrial Zone Aayakar Bhavan Midc, Mahape, Post Ghansoli Mumbai- 400020 Navi Mumbai- 400701 Pan: Aadck3832C (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 147Section 148

trader without purchases. 3. In the facts and circumstances of the case and in law, the AO erred in levying penalty u/s 271(1)(c) and charging interest u/s 234A, B & C. 4. In the facts and circumstance of the case and in law, the CIT(A) NFAC erred ... trader without purchases. 3. In the facts and circumstances of the case and in law, the AO erred in levying penalty u/s 271(1)(c) and charging interest u/s 234A, B & C. 4. In the facts and circumstance of the case and in law, the CIT(A) NFAC erred

The Oriental Insurance Co. Ltd., New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

ITA 1952/DEL/2018[2013-14]Status: DisposedITAT Delhi29 May 2023AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharmaita No. 1952/Del/2018, A.Y. 2013-14 M/S. The Oriental Insurance Co. Vs. Dcit, Ltd. Circle-1, Ltu, A-25/27, Asaf Ali Road, New Delhi New Delhi- 110002 Pan :Aaact0627R

Section 10(38)Section 111ASection 115JSection 143(3)Section 14ASection 32

carry more than normal risk and is not an NPA. The provision for standard assets of Rs.56,59,609/- is therefore disallowed. Penalty u/s 271(1)(c) is initiated for furnishing of inaccurate particulars of income and concealment of the particulars of income.” 10.1 The Ld. first appellate authority

DCIT, Circle- 1, Ltu, New Delhi vs. The Oriental Insurance Co. Ltd., New Delhi

ITA 1750/DEL/2018[2013-14]Status: DisposedITAT Delhi29 May 2023AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharmaita No. 1952/Del/2018, A.Y. 2013-14 M/S. The Oriental Insurance Co. Vs. Dcit, Ltd. Circle-1, Ltu, A-25/27, Asaf Ali Road, New Delhi New Delhi- 110002 Pan :Aaact0627R

Section 10(38)Section 111ASection 115JSection 143(3)Section 14ASection 32

carry more than normal risk and is not an NPA. The provision for standard assets of Rs.56,59,609/- is therefore disallowed. Penalty u/s 271(1)(c) is initiated for furnishing of inaccurate particulars of income and concealment of the particulars of income.” 10.1 The Ld. first appellate authority

Sh. Arashpreet Singh. S/O.Late.Sh. Gurmail Singh, Muktsar vs. Dy. Commissioner of Income Tax .Circle-II, Bathinda

Appeals are disposed of in the terms and observation made as above

ITA 64/ASR/2019[2014-15]Status: DisposedITAT Amritsar25 May 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A

appellant has been palpably defiant and therefore the Assessing Officer was justified in invoking penal provisions and eventually levying penalty u/s 271(1)(c) of the Act. The contention that the appellant that he has filed return of income voluntarily disclosing the income does not hold good in view ... section 271(1)(c) of the Income Tax Act, 1961. The Ld. AR has filed a synopsis on penalty u/s 271(1)(c) that reads as under: “1. The assessee is an individual. His father is Late Sh. Gurmail Singh who was working as an administrator in M/s Satguru Foundation