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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)

Arshadhussain Gulamabbas Shaikh, Surat vs. Income Tax Officer, Ward-2(2)(1), Surat

In the result, the original grounds of appeal raised by the assessee are allowed for statistical purpose

ITA 116/SRT/2023[2010-11]Status: HeardITAT Surat16 May 2023AY 2010-11

Bench: Shri Pawan Singh

Section 144Section 250(6)Section 254(1)Section 271(1)(c)

INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH (SMC), SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER ITA No. 117/Srt/2023 [AY: 2008-09 Penalty u/s 271(1)(c)] (Virtual hearing) Arshadhussain Gulamabbas Shaikh, I.T.O., 303, Mefuz Park Apartment A, Ward-2(2)(1), Vs. Muglisara, Surat, Gujarat-395003. Surat. PAN No. BWOPS

Pushpa Jadhav, Mumbai vs. ITO, Ward 3(2), Kalyan

Appeal of the assessee is allowed

ITA 201/MUM/2023[2011-12]Status: DisposedITAT Mumbai15 May 2023AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amarjit Singhvk-Vk-La- 201@Eaqcbz@2023 ¼Fu-Oa- 2011&12½ Pushpa Jadhav 2004, Clover Building, Everest World, Opp. Bayer, India, Kolshet, Thane-400 601 ..... Vihykfkhz/Appellant Pan No. Acopj6199H Cuke Vs. Income Tax Officer, Ward 3 (2) ..... Izfroknh/Respondent Kalyan-421 306

For Appellant: Shri Tanmay Phadke, Advocate izfroknh }kjk@For Respondent: Shri V. S. Mahajan, Sr. AR
Section 139Section 143(3)Section 148Section 271(1)(c)

duly been deducted on the rental in income and paid to the government exchequer by the deductor. Thus, no penalty u/s 271(1)(c) of the Act is leviable on account of rental income. The Ld. AR in support of his submissions placed reliance on the following decisions: 1 ... assessment order. Once, the AO has accepted the income returned without any addition/disallowance, there is no question of levy of penalty u/s 271(1)(c) of the Act. P a g e | 4 PUSHPA JADHAV 5. We find that the AO while passing the assessment order initially observed that

Jocky Camilo Fernandes, Mumbai vs. ITO 18(2)(4), Mumbai

In the result appeal of the assessee is partly allowed

ITA 3711/MUM/2015[2009-10]Status: DisposedITAT Mumbai15 May 2023AY 2009-10

Bench: Shri Amit Shukla & Shri Gagan Goyaljocky Camilo Fernandes Dd Thakur Wadi, Near Chawl No.03, Agar Bazar, Dadar (W) Mumbai-400 028 Pan: Aadpf5163G ...... Appellant Vs. Ito-18 (2) (4) Mumbai-12 ..... Respondent

For Appellant: Shri Bhupendra ShahFor Respondent: Smt. Vranda U Matkari, Sr. AR
Section 143(3)Section 234ASection 250Section 271(1)(c)Section 274Section 50CSection 54Section 54F

various claimed under five heads on ad hoc basis. 4. To delete interest charged u/s 234A, B & C and initiation of penalty u/s 271(1)(c). 2. Brief facts of the case are that assessee Individual filed its return of income on 29.09.2009 declaring total income at Rs. 1

Patliputra Builders Ltd, Patna vs. ACIT Central Circle-2, Patna

In the result, all the captioned appeals are treated as allowed for statistical purposes

ITA 51/PAT/2021[2008-09]Status: DisposedITAT Patna15 May 2023AY 2008-09

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.49,50&51/Pat/2021 Assessment Years: 2006-07, 2007-08 & 2008-09 Patliputra Builders Limited………....….....................…..........….…… Appellant 301, Maharaja Kameshwar Complex, Frazer Road, Patna. [Pan: Aaccp0629B] Vs. Acit, Central Circle-2, Patna…....…………........….....…...…..…..... Respondent Appearances By: Shri Shravan Kumar Jha, Adv., Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 06, 2023 Date Of Pronouncing The Order : May 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2021 Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In These Appeals Has Agitated The Levy Of Penalty U/S 271(1)(C) Of The Act. 3. At The Outset, The Ld. Counsel For The Assessee Has Invited Our Attention To The Impugned Orders Of The Ld. Cit(A) To Submit That The Impugned Orders In All The Three Appeals Are Ex Parte Orders. The Ld. Counsel Has Submitted That In Fact The Assessee Did Not Receive Any Of The Notice Of Hearing Issued By The Ld. Cit(A). Moreover, The Alleged Dates Of Hearing Mentioned By The Cit(A) Were During The Covid

Section 250Section 271(1)(c)

Income Tax Act (hereinafter referred to as the ‘Act’). 2. The assessee in these appeals has agitated the levy of penalty u/s 271(1)(c) of the Act. 3. At the outset, the ld. Counsel for the assessee has invited our attention to the impugned orders

Patliputra Builders Ltd, Patna vs. ACIT Central Circle-2, Patna

In the result, all the captioned appeals are treated as allowed for statistical purposes

ITA 50/PAT/2021[2007-08]Status: DisposedITAT Patna15 May 2023AY 2007-08

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.49,50&51/Pat/2021 Assessment Years: 2006-07, 2007-08 & 2008-09 Patliputra Builders Limited………....….....................…..........….…… Appellant 301, Maharaja Kameshwar Complex, Frazer Road, Patna. [Pan: Aaccp0629B] Vs. Acit, Central Circle-2, Patna…....…………........….....…...…..…..... Respondent Appearances By: Shri Shravan Kumar Jha, Adv., Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 06, 2023 Date Of Pronouncing The Order : May 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2021 Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In These Appeals Has Agitated The Levy Of Penalty U/S 271(1)(C) Of The Act. 3. At The Outset, The Ld. Counsel For The Assessee Has Invited Our Attention To The Impugned Orders Of The Ld. Cit(A) To Submit That The Impugned Orders In All The Three Appeals Are Ex Parte Orders. The Ld. Counsel Has Submitted That In Fact The Assessee Did Not Receive Any Of The Notice Of Hearing Issued By The Ld. Cit(A). Moreover, The Alleged Dates Of Hearing Mentioned By The Cit(A) Were During The Covid

Section 250Section 271(1)(c)

Income Tax Act (hereinafter referred to as the ‘Act’). 2. The assessee in these appeals has agitated the levy of penalty u/s 271(1)(c) of the Act. 3. At the outset, the ld. Counsel for the assessee has invited our attention to the impugned orders

Patliputra Builders Ltd, Patna vs. ACIT Central Circle-2, Patna

In the result, all the captioned appeals are treated as allowed for statistical purposes

ITA 49/PAT/2021[2006-07]Status: DisposedITAT Patna15 May 2023AY 2006-07

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.49,50&51/Pat/2021 Assessment Years: 2006-07, 2007-08 & 2008-09 Patliputra Builders Limited………....….....................…..........….…… Appellant 301, Maharaja Kameshwar Complex, Frazer Road, Patna. [Pan: Aaccp0629B] Vs. Acit, Central Circle-2, Patna…....…………........….....…...…..…..... Respondent Appearances By: Shri Shravan Kumar Jha, Adv., Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 06, 2023 Date Of Pronouncing The Order : May 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2021 Of The Commissioner Of Income Tax (Appeals)-3, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In These Appeals Has Agitated The Levy Of Penalty U/S 271(1)(C) Of The Act. 3. At The Outset, The Ld. Counsel For The Assessee Has Invited Our Attention To The Impugned Orders Of The Ld. Cit(A) To Submit That The Impugned Orders In All The Three Appeals Are Ex Parte Orders. The Ld. Counsel Has Submitted That In Fact The Assessee Did Not Receive Any Of The Notice Of Hearing Issued By The Ld. Cit(A). Moreover, The Alleged Dates Of Hearing Mentioned By The Cit(A) Were During The Covid

Section 250Section 271(1)(c)

Income Tax Act (hereinafter referred to as the ‘Act’). 2. The assessee in these appeals has agitated the levy of penalty u/s 271(1)(c) of the Act. 3. At the outset, the ld. Counsel for the assessee has invited our attention to the impugned orders

Taj Exim International Ltd, Mumbai vs. DCIT 3(3), Mumbai

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

ITA 6356/MUM/2012[2006-07]Status: DisposedITAT Mumbai11 May 2023AY 2006-07

Bench: Shri G.S. Pannushri Sandeep Singh Karhail

For Appellant: Shri D.C. Agarwal a/wFor Respondent: Ms. Richa Gulati
Section 143(3)Section 250Section 254(1)Section 271(1)(c)Section 80I

grounds:– “1. On the facts and circumstances of the case and judicial proposition, Ld. CIT (Appeals) erred in confirming the levying of penalty u/s 271(1)(c) by Ld. AO on let out property, excess claim of depreciation on Plant & Machinery and Building block of assets and late payment ... above, on the facts and circumstances of the case and judicial proposition, Ld. CIT (Appeals) erred in confirming the levying of penalty u/s 271(1)(c) by Ld. AO on let out property, excess claim of depreciation on Plant & Machinery and Building block of assets and late payment of PF/ESIC

Mohd. Jawed, Bijnor vs. ITO Ward - 3(3), Bijnor

In the result, Appeal of the Assessee is Allowed

ITA 126/DEL/2021[2011-12]Status: DisposedITAT Delhi11 May 2023AY 2011-12
Section 271

Jurisdictional High Court in the case of CIT Vs. Aero Traders Pvt. Ltd. 322 ITR 316 has held that no penalty u/s 271(1)(c) of the Act can be imposed when the income is determined on estimate basis in following manners:- “5. Against this order, the assessee filed

Phi Seeds Pvt. Ltd., Telangana vs. ACIT, Spl. Range-7, New Delhi

In the result, all appeals of the assessee are allowed

ITA 6018/DEL/2019[2010-11]Status: DisposedITAT Delhi10 May 2023AY 2010-11

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Section 10Section 271(1)(c)

Assessment Years 2002-03, 2003-04, 2005-06 & 2010-11, wherein, the Ld. CIT(A) has confirmed the levy of penalty u/s 271(1)(c) of the Act. 2. Since, the issues are common and connected and the appeals were heard together, these are being consolidated and disposed of together

Phi Seeds Pvt. Ltd., Telangana vs. ACIT, Spl. Range-7, New Delhi

In the result, all appeals of the assessee are allowed

ITA 6017/DEL/2019[2005-06]Status: DisposedITAT Delhi10 May 2023AY 2005-06

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Section 10Section 271(1)(c)

Assessment Years 2002-03, 2003-04, 2005-06 & 2010-11, wherein, the Ld. CIT(A) has confirmed the levy of penalty u/s 271(1)(c) of the Act. 2. Since, the issues are common and connected and the appeals were heard together, these are being consolidated and disposed of together

Phi Seeds Pvt. Ltd., Telangana vs. ACIT, Spl. Range-7, New Delhi

In the result, all appeals of the assessee are allowed

ITA 6016/DEL/2019[2003-04]Status: DisposedITAT Delhi10 May 2023AY 2003-04

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Section 10Section 271(1)(c)

Assessment Years 2002-03, 2003-04, 2005-06 & 2010-11, wherein, the Ld. CIT(A) has confirmed the levy of penalty u/s 271(1)(c) of the Act. 2. Since, the issues are common and connected and the appeals were heard together, these are being consolidated and disposed of together

Phi Seeds Pvt. Ltd., Telangna vs. ACIT, Spl. Range-7, New Delhi

In the result, all appeals of the assessee are allowed

ITA 6015/DEL/2019[2002-03]Status: DisposedITAT Delhi10 May 2023AY 2002-03

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

Section 10Section 271(1)(c)

Assessment Years 2002-03, 2003-04, 2005-06 & 2010-11, wherein, the Ld. CIT(A) has confirmed the levy of penalty u/s 271(1)(c) of the Act. 2. Since, the issues are common and connected and the appeals were heard together, these are being consolidated and disposed of together

Paramount Blankets Private Ltd., New Delhi vs. ITO Ward-3, Panipat

The appeal is allowed for statistical purposes

ITA 6869/DEL/2019[2015-16]Status: DisposedITAT Delhi04 May 2023AY 2015-16

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

Section 271(1)(c)

Taxman 324 has held that when the assessee offered an amount of taxation as additional income, the AO was justified in imposing penalty u/s 271(1)(c) of the I.T. Act. In view of the said reasoning, I confirm the penalty levied in this case.” 6. It can be appreciated

ACIT, New Delhi vs. M/S. Kostub Investment Ltd., New Delhi

Accordingly, the appeal of Revenue is dismissed being infructuous

ITA 2281/DEL/2014[2007-08]Status: DisposedITAT Delhi03 May 2023AY 2007-08

Bench: Sh. N.K.Billaiya & Sh.Anubhav Sharma

Section 143(3)Section 253(5)Section 271(1)(c)Section 274Section 68

follows :- 1. “That the order-dated 30.03.2013 passed by the DCIT Circle-5(1), New Delhi for AY 2007-08 imposing the penalty u/s 271(1)(c) of the Income Tax Act is barred by limitation and therefore is void ab-initio. 2. That the notice issued by the Assessing

Bhanwari Devi, Alwar vs. Income Tax Officer Ward 2(2), Alwar

In the result, appeal of the assessee is allowed

ITA 75/JPR/2023[2011-12]Status: DisposedITAT Jaipur03 May 2023AY 2011-12

Bench: The Time Of Hearing Of Appeal.

For Appellant: Shri Rajesh Agarwal( CA)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 144Section 147Section 148Section 250Section 271(1)(c)

completed the assessment order u/s 147 r.w.s. 144 even any notice was never served to the assessee. The AO imposed penalty u/s 271(1)(c) in respect of addition made. Assessee filed appeal against the quantum appeal but learned CIT (A) passed the order without considering the facts ... considered the reply and passed the order very casually without verifying the facts. In view of the above, the penalty u/s 271(1)(c) deserves to be deleted.” 6. On the other hand, the ld. D/R supported the orders of the lower authorities. 7. We have heard learned Counsels

Rajesh Sharma, Kailashpuri vs. ITO Ward 4 (1), Jaipur

In the result the appeal is allowed for statistical purposes in the terms

ITA 62/JPR/2023[2010-11]Status: DisposedITAT Jaipur03 May 2023AY 2010-11

Bench: The Hearing.”

For Appellant: NoneFor Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 147Section 148Section 271(1)(c)Section 69C

order passed u/s 143(3) of the I.T. Act 1961 is bad in law. 2. The learned Authority has erred in levying penalty u/s 271(1)(c) of the IT Act 1961 of Rs. 1,40,865/-. 3. The appellant craves her rights to add, delete, amend

Chitra Jain, Jaipur vs. Income Tax Officer Ward 1(4), Jaipur

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

ITA 26/JPR/2023[2014-15]Status: DisposedITAT Jaipur03 May 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajeev Sogani(CA) &For Respondent: Smt Monisha Choudhary (Addl. CIT)
Section 143(3)Section 271(1)(c)Section 54

making wrong claim of Rs. 1,4,10,754/- and Rs. 7,48,979/- therefore the case found fit for imposing of penalty u/s 271(1)(c). Accordingly, I am satisfied with the facts hence, penalty u/s 271(1)(c) of the Act, 1961 to the tune of notional

Gani Mohammad Popat, Surat vs. ITO, Ward-3, Vapi

In the result, grounds No

ITA 514/SRT/2019[2007-08]Status: DisposedITAT Surat02 May 2023AY 2007-08

Bench: Shri Pawan Singh(Virtual Hearing) Popat Yasin Abdulganibhai, I.T.O., Son & L/H Of Late Gani Mohammad Ward-3, Vs. Popat, Vapi. Bombay Market, Zanda Chowk, Near S.T. Bus Depot, Vapi. Pan No. Akvpp 0747 J Appellant/ Assessee Respondent/ Revenue

Section 147Section 234ASection 234BSection 254(1)Section 271(1)(c)

learned CIT(A) erred in fact and in law in confirming the action of the Id. AO in initiating penalty u/s 271(1)(c) of the Act. 13. Your appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds

Gautam Puranmal Poddar, Kalyan vs. ACIT, Circle 3(2), Kalyan

In the result, the appeals of the assessee are allowed

ITA 584/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Apr 2023AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 583 & 584/Mum/2023 Assessment Years: 2014-15 & 2015-16 Gautam Puranmal Poddar Acit, Circle-3(2), (Huf), 2Nd Floor, Rani Mansion, Plot No. Rl 1 Milap Nagar Midc Vs. Above Canara Bank, Resioential Area Dombivli East Murbad Rd. Kalyan, Kalyan-421 301. Thane-421 301. Pan No. Aaehg 6868 A Appellant Respondent Assessee By : Mr. Jayant Bhatt, Ca Revenue By : Mr. Paresh Deshpande, Dr : Date Of Hearing 27/04/2023 Date Of Pronouncement : 28/04/2023 Order

For Appellant: Mr. Jayant Bhatt, CAFor Respondent: Mr. Paresh Deshpande, DR
Section 10(38)Section 143(3)Section 271Section 271(1)(c)

Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2014-15 and 2015-16 respectively in relation to penalty u/s 271(1)(c) of the Act, 1961 (in short ‘the Act’) levied by the Assessing Officer. Being identical issues in dispute involved in both these appeals ... Assessing Officer initiated penalty u/s order dated 27.12.2016, the Assessing Officer initiated penalty u/s order dated 27.12.2016, the Assessing Officer initiated penalty u/s 271(1)(c) of the Act. After taking into 271(1)(c) of the Act. After taking into consideration, the submission consideration, the submission of the assessee

Gautam Puranmal Poddar, Kalyan vs. ACIT, Circle 3(2), Kalyan

In the result, the appeals of the assessee are allowed

ITA 583/MUM/2023[2014-15]Status: DisposedITAT Mumbai28 Apr 2023AY 2014-15

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Ita Nos. 583 & 584/Mum/2023 Assessment Years: 2014-15 & 2015-16 Gautam Puranmal Poddar Acit, Circle-3(2), (Huf), 2Nd Floor, Rani Mansion, Plot No. Rl 1 Milap Nagar Midc Vs. Above Canara Bank, Resioential Area Dombivli East Murbad Rd. Kalyan, Kalyan-421 301. Thane-421 301. Pan No. Aaehg 6868 A Appellant Respondent Assessee By : Mr. Jayant Bhatt, Ca Revenue By : Mr. Paresh Deshpande, Dr : Date Of Hearing 27/04/2023 Date Of Pronouncement : 28/04/2023 Order

For Appellant: Mr. Jayant Bhatt, CAFor Respondent: Mr. Paresh Deshpande, DR
Section 10(38)Section 143(3)Section 271Section 271(1)(c)

Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2014-15 and 2015-16 respectively in relation to penalty u/s 271(1)(c) of the Act, 1961 (in short ‘the Act’) levied by the Assessing Officer. Being identical issues in dispute involved in both these appeals ... Assessing Officer initiated penalty u/s order dated 27.12.2016, the Assessing Officer initiated penalty u/s order dated 27.12.2016, the Assessing Officer initiated penalty u/s 271(1)(c) of the Act. After taking into 271(1)(c) of the Act. After taking into consideration, the submission consideration, the submission of the assessee