“levy of penalty”

PenaltySection 271Section 2715,057 judgments

The decision most relied on for levy of penalty is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on levy of penalty

CIT v. Manjunatha Cotton & Ginning Factory

359 ITR 565 · 2013 · High Court

2,590

citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.

322 ITR 158 · 2010 · Supreme Court

2,228

citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

Ashok Pai v. CIT

292 ITR 11 · 2007 · Supreme Court

812

citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Rashmikant Kundalia v. Union of India

54 Taxmann.com 200 · 2015 · High Court

702

citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Dilip N. Shroff v. JCIT

291 ITR 519 · 2007 · Supreme Court

565

citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya

216 ITR 660 · 1995 · High Court

511

citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

CIT v. Manu Engg

122 ITR 306 · 1980 · High Court

505

citing judgments

When levying a penalty under Section 271(1)(c), the Assessing Officer must clearly specify whether it is for concealment of income or furnishing inaccurate particulars. An ambiguous notice or order using "and/or" for these limbs, or a standard proforma without striking irrelevant clauses, indicates non-application of mind and renders the penalty unsustainable.

Hindustan Steel Ltd. v. State of Orissa

83 ITR 26 · 1972 · Supreme Court

502

citing judgments

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

Judgments citing levy of penalty

M/S Size Control Gauges and Tools Pvt. Ltd., Pune vs. Dy CIT, Circle- 5, Pune

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

ITA 1865/PUN/2025[2009-10]Status: DisposedITAT Pune21 Jan 2026AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1864 To 1868/Pun/2025 निर्धारण वर्ा / Assessment Years : 2007-08 To 2011-12 M/S. Size Control Gauges Vs. Dcit, Circle-5, Pune. & Tools Pvt. Ltd., Plot No.100/101, Tiny Industries Co-Op. Estate Ltd., Pisoli Road, Kondhwa (Bk), Pune- 411048. Pan : Aaccs3670F Appellant Respondent

For Appellant: Shri Prayag Jha &For Respondent: Shri Sanjay Dhivare (Virtual)

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

said to be leviable on such guess work or estimation. The Court accordingly answered the question in favour of the assessee, rejecting levy of penalty under Section 271(1)(c). 21. The aforesaid discussion would make us conclude, that the Assessing Officer could not have come to a conclusion ... present case attracting proceedings for levy of penalty, when the Assessing Officer had already taken a position on materials which were available before him in the course of assessment proceedings, in computing the amount of tax payable by the assessee, by making appropriate additions on the basis of estimates derived

M/S Size Control Gauges and Tools Pvt. Ltd., Pune vs. Dy CIT, Circle- 5, Pune

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

ITA 1864/PUN/2025[2007-08]Status: DisposedITAT Pune21 Jan 2026AY 2007-08

For Appellant: Shri Prayag Jha &For Respondent: Shri Sanjay Dhivare (Virtual)

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

Spr Publications Private Limited, Hyderabad vs. ITO Ward-3(1), Hyderabad

ITA 2296/HYD/2025[2018-19]Status: DisposedITAT Hyderabad21 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 272A(1)(d)Section 273B

willful attempt not to respond to the notices. 5. The Ld. CIT(A) erred in law and on facts in upholding the levy of penalty u/s 272A(1)(d) of the Act, despite the fact that the quantum assessment itself was completed u/s 147 r.w.s 143(3) r.w.s 144B

Kakinada Infrastructure Holdings Private Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

In the result, appeal of the assessee is partly

ITA 1053/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad21 Jan 2026AY 2021-2022

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.

For Respondent: MS Reema Yadav, Sr. AR

Section 270A

assessee, the Assessing Officer passed the penalty order under section 270A of the Income Tax Act [in short “the Act”], 1961 and levied the penalty of Rs.9.55 crores on account of disallowance of business loss and advertisement expenses. The learned Authorised Representative of the Assessee has submitted that ... delay of 506 days in filing the present appeal. The learned Authorised Representative of the Assessee has further submitted that the levy of penalty by the Assessing Officer was a triggering point for taking a decision by the assessee to challenge the impugned order passed by the learned

Gopal Banik, Kolkata vs. PCIT(Central), Kolkata -2, Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 1430/KOL/2025[2019-20]Status: DisposedITAT Kolkata21 Jan 2026AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2019-20 Gopal Banik…….…………..……..……….………….……….……….……Appellant 20, Apc Road, Kol- 700009.. [Pan: Aegpb1186E] Vs. Pcit (Central)-2, Kolkata…………………………..…….....……...…..…..Respondent Appearances By: Shri K K Khemka, Advocate, Appeared On Behalf Of The Appellant. Shri Sandeep Kumar Mehta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 05, 2026 Date Of Pronouncing The Order : January 21, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2024 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2020–21. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 174 Days & The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Going Over The Said Affidavit, We Find Sufficient Reasons Behind The Delay & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 132Section 250Section 270ASection 270A(1)Section 270A(7)Section 271(1)(c)Section 274Section 69A

this case. Therefore, SCN proposing penalty are found to be vague and doesn’t satisfy the requirement of law and therefore, consequent levy of penalty is fragile in the eyes of law and is held to be ab initio void. Thus, assessee’s appeal ... issuing the penalty notice u/s.270A of the Act either for ‘underreporting of income’ or for ’misreporting of income’ to defend the assessee against levy of penalty. Hence, we quash the penalty imposed u/s 270A of the Act. 4 Gopal Banik 8. In the result, the appeal filed by the assessee

Kshitij Interiors Pvt. Ltd., Mumbai vs. DCIT-Circle 2(1)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 7401/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Jan 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarkshitij Interiors Pvt. Ltd. Dcit- Circle 210, Mogra Village, Old 2(1)(1), Nagardas Road, Mumbai- Vs. Aayakar Bhavan, 400069 Maharshi Karve Road, Mumbai-400 020 Pan/Gir No. Aabck8174D (Applicant) (Respondent) Assessee By Shri Vishwas Mehendale Revenue By Shri Hemanshu Joshi, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 21.01.2026

Section 115JSection 133ASection 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 270A(8)Section 270A(9)(a)

there was no difference 4 Kshitij Interiors Pvt. Ltd between the returned income and the assessed income, and therefore the basic condition for levy of penalty under section 270A was not satisfied. It was further submitted that the disclosure was made before completion of assessment and could not be treated ... meet. 16. Even otherwise, on merits, we find force in the contention of the assessee that the basic jurisdictional requirement for levy of penalty under section 270A(2) is absent, inasmuch as the income assessed is not greater than the income determined in the return processed under section

DCIT Central Circle 1 Delhi, Delhi vs. Sahara India Financial Corporation Ltd, Lucknow

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11

Section 142Section 250Section 269SSection 271D

amounts representing receipt of deposits amounting to Rs.1735,27,79,257/-. 1.1 Before the Ld. CIT(A) the assessee not only challenged the levy of penalty on merits but also raised a ground (ground no.2 in Form 35) alleging that the impugned penalty order was passed by the Additional ... read out para 10 from this order in which it is written that since only the Joint Commissioner could initiate proceedings for levy of penalty u/s 271D of the Act then the limitation had to be decided from the date of such initiation by the Joint Commissioner of Income Tax.An

Bmw Industries Limited, Kolkata vs. DCIT, Central Circle 4(1), Kolkata

Appeals of the assessee are allowed

ITA 2585/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsiyan &For Respondent: Shri Ms. Archana Gupta, DR

Section 143(3)Section 147Section 148Section 271(1)(c)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

Sandip Jhunjhunwala, Kolkata vs. DCIT, Central Circle 4(3), Kolkata

In the result, appeal of assessee is allowed and that of Revenue is dismissed”

ITA 2483/KOL/2025[2012-2013]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri S.K. Tulsian &For Respondent: Shri S.B. Chakraborthy, DR

Section 132Section 132(4)Section 133ASection 139(1)Section 143(3)Section 271(2)Section 271A

course of scrutiny proceedings and even in penalty proceedings. This was also explained before CIT(A) during the appellate proceedings qua the levy of penalty. In view of the above, now we have to discuss the case law of coordinate of ITAT Jabalpur Bench in the case of ACIT ... held:- “Mere addition agreed to by the assessee during the course of survey would not empower the Assessing Officer to levy the penalty under section 271(1)© of the Income-tax Act, 1961 ... The fact that the assessee had agreed to additions to income was not proof of concealment.” Even

D.D.155Athoorp.U.Publicservantsco-Opthrift&Creditsociety Limited, Sithayankottai vs. Ward 1, Dindigul

In the result the appeal of the assessee is stands allowed

ITA 2801/CHNY/2025[2020-2021]Status: DisposedITAT Chennai20 Jan 2026AY 2020-2021

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Raviassessment Years: 2020-21 D.D.155 Athoor P.U.Public Servants Income Tax Officer, Cooperative Thrift & Credit Society Ward-1, Limited, Dindigul No.8-1-19 Market Road, Sithavankottai Aathoor-Tk, Dindigul Tamil Nadu-624 708. [Pan: Aacad2029F]

For Appellant: NoneFor Respondent: Ms.R.Anitha, Addl.CIT

Section 143(3)Section 270ASection 270A(6)(a)Section 270A(8)Section 80(2)(d)Section 80PSection 80P(2)(d)

under the provisions of section 270A(6)(a) of the Act and no penalty was leviable. However, rejecting he above contentions, the AO levied a penalty of Rs.8,16,066/- vide order 01.03.2023. Being aggrieved by the levy of penalty, an appeal was preferred before the CIT(A) who vide ... rival submissions and perused the material available on record. The issue that arises for our consideration is whether the AO is justified in levying a penalty u/s 270A of the Act. Admittedly, the disparity between returned income and assessed income had arisen on account of addition made

Dy. Commissioner of Income Tax, Mumbai vs. Kanakia Spaces Realty Private Limited, Mumbai

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

ITA 6133/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Jan 2026AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2011-12 Dy. Commissioner Of Income Tax Kanakia Spaces Realty Room No. 420, Kautilya Bhawan, Private Limited Vs. G Block, Bandra Kurla Complex, Plot No. 8, Vilco Centre, 3Rd Mumbai- 400051 Floor, Subhash Road, Opp Garware House, Vile Parle East, Mumbai- 400057 Pan No. Aaccc 4199 F Appellant Respondent Assessee By : Ms. Shweta Vardhan : Shri. Hemanshu Joshi, Sr Dr Revenue By Date Of Hearing : 25/11/2025 : 20/01/2026 Date Of Pronouncement Order

For Appellant: Ms. Shweta Vardhan

Section 143(3)Section 147Section 271(1)(c)

reproduced as below: “6.1 Ground No.1 raised by the appellant pertains to levy of 6.1 Ground No.1 raised by the appellant pertains to levy of penalty 6.1 Ground No.1 raised by the appellant pertains to levy of u/s 271(1)(c) of the Act amounting

Smt. Urmila Dhelia, Mumbai vs. Income Tax Officer Ward 23(3)(1), Mumbai

In the result, the appeal filed by the assessee stands allowed

ITA 4204/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Jan 2026AY 2018-19

Bench: Shri Sandeep Gosain & Shri Arun Khodpia

Section 143(3)Section 250Section 270Section 270ASection 270A(2)(a)Section 270A(9)Section 270A(9)(a)Section 274

very outset, Ld. AR submitted that the noticed which is at paper book page No. 48 and 49 was issued for levy of penalty u/s 274 r.w.s 270A of the Act, did not specify the limb of Sec. 270A(9) of the Act under which the assessee can be said ... that AO had not specified the limb of Sec. 270A(9) of the Act at the time when the notice was issued for levy of penalty u/s 274 r.w.s 270(A) of the Act under which the assessee can be said to have misreported the income. On the co- joint

Riteshkumar Bhupendrabhai Choksi, Vadodara vs. ITO, Ward 1(5), Bharuch

In the result, the appeal of the assessee in ITA No

ITA 342/SRT/2025[2012-13]Status: HeardITAT Surat19 Jan 2026AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri P.M. Jagasheth, CAFor Respondent: Shri Ashish Kumar, Sr DR

Section 144Section 147Section 148Section 271(1)(c)Section 69

made in the assessment order. Since we have deleted the entire quantum additions while disposing of ITA No. 341/SRT/2025, the very foundation for levy of penalty no longer survives. Accordingly, the penalty levied u/s 271(1)(c) of the Act is hereby deleted and the appeal filed by the assessee

Riteshkumar Bhupendrabhai Choksi, Vadodara vs. ITO, Ward 1(5), Bharuch

In the result, the appeal of the assessee in ITA No

ITA 341/SRT/2025[2012-13]Status: HeardITAT Surat19 Jan 2026AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri P.M. Jagasheth, CAFor Respondent: Shri Ashish Kumar, Sr DR

Section 144Section 147Section 148Section 271(1)(c)Section 69

Capgemini Technology Services India Limited (Successor to Liquidhub India Private Limited), Pune vs. Assistant Commissioner of Income Tax, Circle 1(1), Pune

In the result, the Appeal filed by the Assessee is allowed

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

initio and rendering the Penalty Order u/s 270A to be a nullity in the eyes of the law and liable to be quashed. Levy of Penalty with respect to disallowance of "Health and Educational Cess": 3. The CIT(A) has erred in confirming the penalty levied under section 270A ... 111/2022 dated 28-09-2022 issued by Central Board of Direct Taxation (CBDT) and consequently the Appellant is eligible for immunity from levy of penalty under provisions of section 155(18) of the Act. 7. The Learned CIT(A) has failed to appreciate that the proviso to subsection

Rikhabchand Vachraj Mehta, Mumbai vs. The Income Tax Officer-Circle 19(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7238/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyrikhabchandvachraj Mehta Vs. The Income Tax Officer-Circle 19(3) 1401/1402 Necklace View Piramal Chamber, Gharonda Bldg., 96 Mumbai-400012. Walkeshwar Road, Girgaon S.O, Mumbai-400004. Pan/Gir No:Aacpm0691D (Appellant) (Respondent)

Section 143(3)Section 14ASection 250Section 271(1)(C)Section 271(1)(c)

Centre*in short, ‘CIT(A), NFAC’+, Delhi, dated 15.10.2025 for the Assessment Year 2012-13, whereas the assessee has challenged the sustenance of levy of penalty u/s. 271(1)(c) of the Act amounting to Rs. 22,563/- of the Act. 2. None appeared on behalf of the assessee ... penalty has not been initiated during the course of assessment proceedings, there is no basis for the AO to proceed further and levy the penalty as has happened in the instant case and the penalty deserve to be set aside. ITA No.7238/MUM/2025/AY 2012-13 RikhabchandVachraj Mehta 5. Further, we find

Rishiraj Hitendra Bhandari, Mumbai vs. Income Tax Officer Ward 24(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 7156/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyrishirajhitendra Bhandari Vs. Income Tax Officer, Ward 24(3)(1) 224/234, Tower B, Piramal Chamber, Lalbaug, Parel, Kalpataru Horizon, Worli, Mumbai-400012. Mumbai-400018. Pan/Gir No:Aocpb2452H (Appellant) (Respondent)

Section 115BSection 250Section 271ASection 69

Centre*in short, ‘CIT(A), NFAC’+, Delhi, dated 22.09.2025 for the Assessment Year 2017-18, wherein the assessee has challenged the sustenance of levy of penalty u/s. 271AAC of the Act. 2. During the course of hearing, the ld. AR submitted that the addition has been made ... light of the order in the quantum proceedings and against which, the Revenue is not in appeal, there is no basis for levy of penalty u/s. 271AAC of the Act. 3. The ld. DR has been heard who has relied on the penalty order so passed

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7070/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Jan 2026AY 2020-21

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

challenged the order passed by the Commissioner of Income Tax (Appeals)-53, Mumbai [hereinafter referred to as ‘the CIT(A)’] deleting the levy of penalty under Section 271(1)(c) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], whereas appeal(s) for the Assessment Year ... penalty holding as under: “Decision: 6. Ground no.1 is general in nature, hence the same is Dismissed. 7. Ground no.2 is related to levy of penalty u/s.271(1)(c) of the Act. Assessment Year 2014-2015 to 2019-2020 7.1 The AO has passed assessment order u/s.143(3) r.w.s153A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7069/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7068/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri

Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68