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“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

DCIT Corporate Circle 4(2), Chennai vs. Nagarjuna Oil Corporation Ltd., Chennai

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

ITA 2704/CHNY/2017[2011-12]Status: DisposedITAT Chennai21 Nov 2022AY 2011-12

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: NoneFor Respondent: Shri R. Mohan Reddy, CIT
Section 143(3)Section 271(1)(c)

common issue in these four appeals, is as regards to the common order of CIT(A) for both the assessment years confirming the levy of penalty u/s.271(1)(c) of the Act in regard to interest income claimed by assessee, on the pre-commencement of business period, as capital receipt ... also confirmed the addition and subsequently, the ITAT also confirmed the addition. The AO initiated penalty proceedings and levied the penalty u/s.271(1)(c) of the Act by observing as under:- The assessee company has quoted various decisions of the Hon'ble Supreme Court in support of its claim

DCIT Corporate Circle 4(2), Chennai vs. Nagarjuna Oil Corporation Ltd., Chennai

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

ITA 2703/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Nov 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: NoneFor Respondent: Shri R. Mohan Reddy, CIT
Section 143(3)Section 271(1)(c)

common issue in these four appeals, is as regards to the common order of CIT(A) for both the assessment years confirming the levy of penalty u/s.271(1)(c) of the Act in regard to interest income claimed by assessee, on the pre-commencement of business period, as capital receipt ... also confirmed the addition and subsequently, the ITAT also confirmed the addition. The AO initiated penalty proceedings and levied the penalty u/s.271(1)(c) of the Act by observing as under:- The assessee company has quoted various decisions of the Hon'ble Supreme Court in support of its claim

Nagarjuna Oil Corporation Ltd., Chennai vs. ACIT Corporate Circle 4(2), Chennai

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

ITA 2605/CHNY/2017[2012-13]Status: DisposedITAT Chennai21 Nov 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: NoneFor Respondent: Shri R. Mohan Reddy, CIT
Section 143(3)Section 271(1)(c)

common issue in these four appeals, is as regards to the common order of CIT(A) for both the assessment years confirming the levy of penalty u/s.271(1)(c) of the Act in regard to interest income claimed by assessee, on the pre-commencement of business period, as capital receipt ... also confirmed the addition and subsequently, the ITAT also confirmed the addition. The AO initiated penalty proceedings and levied the penalty u/s.271(1)(c) of the Act by observing as under:- The assessee company has quoted various decisions of the Hon'ble Supreme Court in support of its claim

Nagarjuna Oil Corporation Ltd., Chennai vs. ACIT Corporate Circle 4(2), Chennai

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

ITA 2604/CHNY/2017[2011-12]Status: DisposedITAT Chennai21 Nov 2022AY 2011-12

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: NoneFor Respondent: Shri R. Mohan Reddy, CIT
Section 143(3)Section 271(1)(c)

common issue in these four appeals, is as regards to the common order of CIT(A) for both the assessment years confirming the levy of penalty u/s.271(1)(c) of the Act in regard to interest income claimed by assessee, on the pre-commencement of business period, as capital receipt ... also confirmed the addition and subsequently, the ITAT also confirmed the addition. The AO initiated penalty proceedings and levied the penalty u/s.271(1)(c) of the Act by observing as under:- The assessee company has quoted various decisions of the Hon'ble Supreme Court in support of its claim

Lakshmanan, Chennai vs. ITO, Ncw - 1 (3), Chennai

In the result, appeal filed by the assessee in ITA No

ITA 2744/CHNY/2019[2015-16]Status: DisposedITAT Chennai18 Nov 2022AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2882/Chny/2018 & नि◌धा"रण वष" /Assessment Year: 2015-16 V. Mr.Lakshmanan, The Income Tax Officer, No.7/2, 1St Floor, Akm Nest, Non-Corporate Ward-1(3), Jawaharlal Nehru Street, T.Nagar, Chennai. Chennai-600 017. [Pan: Aabpl 4326 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Vasudevan, AdvFor Respondent: Mr.AR.V.Sreenivasan
Section 43(5)Section 45

appeal filed by the assessee in ITA No.2744/Chny/2019 are as under: 1. The order of the Commissioner of Income Tax(Appeals) confirming the levy of penalty under sec.271 B of the Act is contrary to law, erroneous and unsustainable on the facts of the case ... does not satisfy any of the conditions to warrant the preparation and filing of audit report as per sec.44AB and hence confirming the levy of penalty on the pretext that an addition is made in the assessment is wholly unjustified and untenable in law. 4. The CIT(A) further failed

Lakshmanan Revathi, Chennai vs. ITO N.C.W 1(3), Chennai

In the result, appeal filed by the assessee in ITA No

ITA 2883/CHNY/2018[2015-16]Status: DisposedITAT Chennai18 Nov 2022AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2882/Chny/2018 & नि◌धा"रण वष" /Assessment Year: 2015-16 V. Mr.Lakshmanan, The Income Tax Officer, No.7/2, 1St Floor, Akm Nest, Non-Corporate Ward-1(3), Jawaharlal Nehru Street, T.Nagar, Chennai. Chennai-600 017. [Pan: Aabpl 4326 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Vasudevan, AdvFor Respondent: Mr.AR.V.Sreenivasan
Section 43(5)Section 45

appeal filed by the assessee in ITA No.2744/Chny/2019 are as under: 1. The order of the Commissioner of Income Tax(Appeals) confirming the levy of penalty under sec.271 B of the Act is contrary to law, erroneous and unsustainable on the facts of the case ... does not satisfy any of the conditions to warrant the preparation and filing of audit report as per sec.44AB and hence confirming the levy of penalty on the pretext that an addition is made in the assessment is wholly unjustified and untenable in law. 4. The CIT(A) further failed

Lakshmanan, Chennai vs. ITO N.C.W 1(3), Chennai

In the result, appeal filed by the assessee in ITA No

ITA 2882/CHNY/2018[2015-16]Status: DisposedITAT Chennai18 Nov 2022AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2882/Chny/2018 & नि◌धा"रण वष" /Assessment Year: 2015-16 V. Mr.Lakshmanan, The Income Tax Officer, No.7/2, 1St Floor, Akm Nest, Non-Corporate Ward-1(3), Jawaharlal Nehru Street, T.Nagar, Chennai. Chennai-600 017. [Pan: Aabpl 4326 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.T. Vasudevan, AdvFor Respondent: Mr.AR.V.Sreenivasan
Section 43(5)Section 45

appeal filed by the assessee in ITA No.2744/Chny/2019 are as under: 1. The order of the Commissioner of Income Tax(Appeals) confirming the levy of penalty under sec.271 B of the Act is contrary to law, erroneous and unsustainable on the facts of the case ... does not satisfy any of the conditions to warrant the preparation and filing of audit report as per sec.44AB and hence confirming the levy of penalty on the pretext that an addition is made in the assessment is wholly unjustified and untenable in law. 4. The CIT(A) further failed

Sabara Impex Ltd, Mumbai vs. ITO WD 2(3)(2), Mumbai

In the result, appeal filed by the assessee is fully dismissed

ITA 3267/MUM/2013[1996-97]Status: DisposedITAT Mumbai17 Nov 2022AY 1996-97

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: NoneFor Respondent: Ms. Nilu Jaggi, Sr.DR
Section 131Section 143(3)Section 147Section 148Section 68Section 80H

facts. 02. The learned lower authorities have grossly erred in levying / confirming the levy of penalty us 271 (1) of the IT Act, 1961, at Rs. 1, 90, 00,000/- purely on the basis of addition made to the returned income during the course of the assessment proceeding, without bringing ... particulars of income or for furnishing inaccurate particulars of such income. 03. The learned lower authorities have grossly erred in levying / confirming the levy of penalty under section 271(1) (c) of the IT Act, 1961, at Rs. 1,90,00,000 Reasons assigned for the impugned levy of penalty

Sd Svp Nagar Redevelopment P. Ltd., Mumbai vs. ACIT -3(3)(1), Mumbai

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

ITA 466/MUM/2021[2015-16]Status: DisposedITAT Mumbai16 Nov 2022AY 2015-16

Bench: Shri Vikasw Awasthy () & Shri Amarjit Singh ()

Section 143(3)Section 2Section 271Section 271(1)Section 271(1)(c)Section 274

Income Tax Act, 1961 & as affirmed by the Hon'ble CIT(A) is bad in law as the basic conditions for levy of penalty u/s 271(1) (c) are not satisfied. The appellant prays that penalty levied u/s 271(l)(c) may be deleted. 2. On the facts & circumstances

Vishwajit C. Chindarkar, Mumbai vs. DCIT -22(2), Mmbai

ITA 1694/MUM/2022[2008-09]Status: DisposedITAT Mumbai15 Nov 2022AY 2008-09

Bench: Shri Vikas Awasthy & Shri S.Rifaur Rahman आअसं.1694/मुं/2022 ("न.व. 2008-09) Mr. Vishwajit C. Chindarkar, M/S. Ch & Co., Shop No.5, Gr.Floor, Neelkanth Shopping Arcade, Mumbai 400 071. Pan: Acxpc-8042-M. ...... अपीलाथ" /Appellant बनाम Vs. The Dcit – 22(2), Mumbai. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : None ""तवाद" "वारा/Respondent By : Ms. Vranda U Matkarni सुनवाई क" "त"थ/ Date Of Hearing : 22/08/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 15/11/2022 आदेश/ Order Per Vikash Awasthy, Jm:

For Appellant: NoneFor Respondent: Ms. Vranda U Matkarni
Section 143(3)Section 271(1)(c)

time filed appeal against the order levying penalty u/s. 271(1)(c) of the Act. The CIT(A) vide impugned order upheld the levy of penalty. Hence, the present appeal by the assessee. 3. Since, the addition on which penalty u/s. 271(1)(c) of the Act was levied

I Maritime Consultancy Pvt Ltd, Mumbai vs. ITO-15(2) (1), Mumbai

Appeal of the Assessee is allowed

ITA 401/MUM/2022[2013-14]Status: DisposedITAT Mumbai14 Nov 2022AY 2013-14

Bench: Shri Amit Shukla, Jm & Shri M Balaganesh, Am आयकरअपीलसं./ I.T.A. No.401/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2013-14) I Maritime Ito-15(2) (1) Mumbai. Consultancy P. Ltd 11B 114, We Work 10Th Floor, Mumbai. Tower 1,Seawoods Grand 11B 114, We Work 10Th बिधम/ Central, Sector 40, Nerul, Floor, Tower 1, Seawoods Vs. Mumbai Maharashtra. Grand Central, Sector 40, 400706 Nerul, Mumbai 400706 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaac17284B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri. Jayant Bhatt प्रत्यथीकीओरसे/Respondent By : Shri. Manoj Sinha (Sr Ar) सुनवाईकीतारीख/ : 17.08.2022 Date Of Hearing घोषणाकीतारीख / : 14.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: 1. The Aforesaid Appeal Has Been Filed By The Assessee Against Order Date 04.02.2019 Passed By The Cit (Appeals), 24 Mumbai, In Relation To Penalty Proceedings U/S 271(1) (C) For The Ay 2013-2014. The Assessee Has Challenged The Levy Of Penalty Of Rs. 4,50,000/-

For Appellant: Shri. Jayant BhattFor Respondent: Shri. Manoj Sinha (SR AR)
Section 250Section 271(1)

Appeals), 24 Mumbai, in relation to penalty proceedings u/s 271(1) (c) for the AY 2013-2014. The Assessee has challenged the levy of penalty of Rs. 4,50,000/- 2 I.T.A. No. 401/Mum/2022 I Maritime Consultancy P. Ltd. levied u/s 271(1) (c) on account of addition ... initiate the penalty, whether for furnishing of inaccurate particulars of income or consequent of income. 7. Thereafter, the Ld. Assessing Officer has levied the penalty holding that Assessee has furnished in accurate particulars for a making a wrong claim and levied the penalty

M/S Karnataka Emta Coal Mines Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2139/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

under: “7. In the Mittal Steel Ltd.'s case (supra), the proviso to section 201 was under consideration. The said proviso empowers levy of penalty if the TDS deduction is not effected for any valid reason. However, section 201(1A) is a distinct provision to levy interest for delayed remittance

M/S Karnataka Emta Coal Mines Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2138/BANG/2018[2013-14]Status: DisposedITAT Bangalore14 Nov 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

under: “7. In the Mittal Steel Ltd.'s case (supra), the proviso to section 201 was under consideration. The said proviso empowers levy of penalty if the TDS deduction is not effected for any valid reason. However, section 201(1A) is a distinct provision to levy interest for delayed remittance

M/S Karnataka Emta Coal Mines Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2137/BANG/2018[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

under: “7. In the Mittal Steel Ltd.'s case (supra), the proviso to section 201 was under consideration. The said proviso empowers levy of penalty if the TDS deduction is not effected for any valid reason. However, section 201(1A) is a distinct provision to levy interest for delayed remittance

M/S Karnataka Emta Coal Mines Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2136/BANG/2018[2011-12]Status: DisposedITAT Bangalore14 Nov 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

under: “7. In the Mittal Steel Ltd.'s case (supra), the proviso to section 201 was under consideration. The said proviso empowers levy of penalty if the TDS deduction is not effected for any valid reason. However, section 201(1A) is a distinct provision to levy interest for delayed remittance

M/S Karnataka Emta Coal Mines Limited, Bangalore vs. The Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, assessee’s appeals are partly allowed for statistical purposes

ITA 2135/BANG/2018[2010-11]Status: DisposedITAT Bangalore14 Nov 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri Gudimella V.P. Pavan Kumar &
Section 32(1)(ii)Section 35ESection 37

under: “7. In the Mittal Steel Ltd.'s case (supra), the proviso to section 201 was under consideration. The said proviso empowers levy of penalty if the TDS deduction is not effected for any valid reason. However, section 201(1A) is a distinct provision to levy interest for delayed remittance

M/S. Kaypan Vanijya Pvt. Ltd., Mumbai vs. ITO Ward-6(3)(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 1723/MUM/2019[2014-15]Status: DisposedITAT Mumbai11 Nov 2022AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Tejinder Pal Singh Anand
Section 143(3)Section 250Section 271(1)(c)Section 36(1)(vii)Section 36(2)

appeal either before or during the course of hearing of the appeal.” 4. The only grievance of the assessee is against the levy of penalty under section 271(1)(c) of the Act. M/s. Kaypan Vinijya Pvt. Ltd. ITA No.1723/Mum./2022 5. The brief facts of the case ... were initiated. The Assessing Officer (‘AO’) vide penalty order dated 09/06/2017, passed under section 271(1)(c) of the Act, levied a penalty of Rs. 88,155, on the basis that no justification with regard to the satisfaction of conditions laid down under section 36(2) was furnished

M/S. Sumit Exports, Mumbai vs. The ACIT 19(3), Mumbai

ITA 645/MUM/2022[2013-14]Status: DisposedITAT Mumbai10 Nov 2022AY 2013-14

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Sumit Export V. Acit – 19(3) Dw-5030, 5Th Floor Matru Mandir, Tardev Road D.Tower, Bharat Diamond Bourse Mumbai – 400 007 Bandra Kurla Complex Bandra (E), Mumbai -400051 Pan: Aacfs3599Q (Appellant) (Respondent) Assessee Represented By : Shri Rahul Sarda Department Represented By : Shri Manoj Sinha

Section 143(1)Section 143(2)Section 2(14)Section 2(47)

appeal had been filed by the department against the order of CIT (A) in deleting the penalty of Rs. 11.94,545/-. The AO levied the penalty in question qua the addition made. The Learned CIT(A) deleted the penalty, holding that the penalty was not leviable on addition made ... conceal its income. The Hon'ble ITAT, in the order deleted the addition made, in toto. Therefore, the very basis of the levy of penalty in question no longer survives. Accordingly, the grievance of the department is rejected and the order of the Ld.CIT(A) deleting the penalty is upheld

M/S. Icici Securities Ltd, Mumbai vs. The Income Tax Officer (International Tax Ward)2(2) (2), Mumbai

In the result, the appeal is allowed in the terms indicated above

ITA 1511/MUM/2022[2015-16]Status: DisposedITAT Mumbai09 Nov 2022AY 2015-16
Section 195Section 201Section 201(1)Section 201(4)Section 204Section 49

source but he does not pay, or does not pay in time, the taxes so deducted at source. ………………….. Section 271C deals with levy of penalty for total or partial failure to deduct tax at source i.e., for non- deduction and short-deduction of tax at source. This provision is clearly

M/S. Silverline Industries Ltd., Mumbai vs. ITO - 3(3)(2), Mumbai

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

ITA 1738/MUM/2020[2003-04]Status: DisposedITAT Mumbai08 Nov 2022AY 2003-04

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalem/S Silverline Industries Vs. Ito – 3(3)(2) Ltd.,Unit No. 121, Sdf Iv Mumbai – 400021. Seepz Andheri (E), Mumbai – 400096. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs7365M Appellant .. Respondent Appellant By : None Respondent By : Shri Suresh Periasamy.Dr Date Of Hearing 13.10.2022 Date Of Pronouncement 17.10.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-18, Mumbai Passed U/S 271(1)(C) & 250 Of The Act. The Assessee Has Raised Grounds Of Appeal Challenging The Levy Of Penalty U/Sec 271(1)(C) Of The Act.

For Appellant: NoneFor Respondent: Shri Suresh Periasamy.DR
Section 143(1)Section 143(2)Section 144Section 271(1)(C)Section 271(1)(c)

Appeals)-18, Mumbai passed u/s 271(1)(C) and 250 of the Act. The assessee has raised grounds of appeal challenging the levy of penalty u/sec 271(1)(C) of the Act. 2. On perusal of the facts, the appeal was filed by the assessee ... grounds of appeal that the CIT(A) has over looked the M/s. Silverline Industries Ltd., Mumbai. information of the assessee and confirmed the levy of penalty. Prima-facie the CIT(A) has passed the order considering the fact that there is no appearance in spite of providing adequate opportunity