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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

Karthick Natarajan, Anna Nagar, Madurai vs. DCIT, Int Taxn Circle, Income Tax Office, Cr Building, Madurai

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

ITA 2106/CHNY/2024[2017-18]Status: DisposedITAT Chennai29 May 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. T.Vasudevan, AdvocateFor Respondent: Mr. AR.V.Sreenivasan, CIT
Section 271(1)(C)

Commissioner of Income Tax (Appeals) [CIT(A)] Chennai-16 dated 21.06.2024 for Assessment Year 2017- 18. 2. The above appeal is against the levy of penalty u/s 271(1)(C) of the Act for AY 2017-18. The ld. counsel for the assessee filed a letter dated 07.05.2025 and submitted

Neha Goel, Faridabad vs. PCIT, Faridabad

In the result, appeal of the assesse is allowed

ITA 2624/DEL/2024[2014-15]Status: DisposedITAT Delhi28 May 2025AY 2014-15

Bench: Sh. Shamim Yahya & Sh. Sudhir Kumarassessment Year: 2014-15 Neha Goel, Vs. Pcit, H. No. 585 Sector 15 Faridabad. Faridabad 121007. Pan No.Ahcpg6493Q (Appellant) (Respondent)

Section 10(38)Section 144BSection 147Section 148Section 148(2)Section 151Section 263

said case, appeal was filed by the assessee before the Tribunal against the levy of penalty. In the appeal challenging the penalty order, the assessee challenged the validity of block assessment order which had determined the tax liability of the assessee on the basis of which penalty was levied subsequently ... therefore it is open to the assessee to set up the question of validity of the assessment in the appeal against the levy of penalty. 8.9. We also derive support from another judgement of Hon'ble Bombay High Court in the case of Inventors Industrial Corporation

Sh. Dilip Singh, Pali vs. ITO, Ward-1, Pali

In the result, the appeal is partly allowed

ITA 613/JODH/2024[2017-18]Status: DisposedITAT Jodhpur27 May 2025AY 2017-18

Bench: Shri Rajpal Yadav, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 142Section 142(1)Section 272A(1)(d)Section 273

Faceless Appeal Central, Delhi (hereinafter referred to as "NFAC/CIT(A)"] dated 11.07.2024 in respect of assessment year 2017-18 challenging therein confirmation of levy of penalty of Rs. 40,000/- u/s 272A(1)(d) of the Income Tax Act, 1961. 2. Heard both the sides and perused the material available

Gunjan Agarwal, Surat vs. ITO, Ward 1(2)(2), Surat

In the result, the appeal of the assessee is hereby allowed

ITA 59/SRT/2025[2008-09]Status: DisposedITAT Surat27 May 2025AY 2008-09

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.59/Srt/2025 िनधा"रण वष" /Assessment Year : 2008-09 Gunjan Agarwal The Ito बनाम/ (Prop. Shree Grih Shobha Ward-1(2)(2) V/S. Sarees Surat 457, Millennium Textile Market-2 Ring Road, Surat - 395 002 "थायी लेखा सं./Pan: Aewpa 8182 K (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Dalzin Madan, Ca Revenue By : Shri Mukesh Jain, Cit (Dr) सुनवाई की तारीख/Date Of Hearing : 30/04/2025 घोषणा की तारीख /Date Of Pronouncement: 27/05/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 21/11/2024 For The Assessment Year (Ay) 2008-09. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. On Facts & Circumstances Of The Case & In Law, The Learned Cit(A), Nfac Has Grossly Erred In Passing The Impugned Appellate Order On An Ex- Gunjan Agarwal Vs. Ito Asst. Year : 2008-09

For Appellant: Ms. Dalzin Madan, CAFor Respondent: Shri Mukesh Jain, CIT (DR)
Section 271(1)(c)

addition has been confirmed by the Tribunal on estimation basis, however, the nature of the said addition in our view, does not warranted levy of penalty u/s.271(1)(c) of the Income Tax Act, 1961. Therefore, it is not a case of concealment of income or furnishing of inaccurate particulars

High Range Foods Private Limited, Ernakulam vs. DCIT Corporate Cir 1(1), Kochi

In the result, the appeal by the assessee is allowed

ITA 490/COCH/2024[2014-15]Status: DisposedITAT Cochin27 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2014-15 High Range Foods Private Dcit, Corporate Circle-1(1) Limited, Kochi 28/3030, Vs. Cheruparambath Road, Kadavanthra, Ernakulam-682020 Pan : Aaach6076L (Appellant) (Respondent) For Assessee : Shri P.M. Veeramani, Ca For Revenue : Smt. Leena Lal (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025

For Appellant: Shri P.M. Veeramani, CAFor Respondent: Smt. Leena Lal
Section 143(3)Section 250Section 271(1)(c)Section 36(1)(va)Section 4

first issue that arises for our consideration pertains to the levy of penalty u/s.271(1)(c)of the Actin respect of the addition on account of deposits received from dealers in lieu of installing deep- freezers. 3. The brief facts of the case pertaining to this issue, as emanating from ... AOu/s.271(1)(c)of the Acton this issue is deleted. 4. The next issue that arises for our consideration pertains to the levy of penalty u/s.271(1)(c)of the Act in respect of disallowance on 3 account of belated payment of employees' contribution towards PF/ESIC

Dy. Commissioner of Income Tax, Central Circle 3, Ludhiana vs. Leeford Healthcare Ltd., Punjab, Ludhiana

The appeal of the department is dismissed

ITA 551/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh27 May 2025AY 2018-19

Bench: SHRI RAJPAL .YADAV, VP &SHRI. KRINWANT SAHAY, AM आयकर अपील सं/ . ITA No. 549/Chd/2024 निर्धारण वर्ष / Assessment Year : 2018-19 Dy. Commissioner of Income Tax बनाम Central Circle 3, Ludhiana Punjab Amit Kumar C/o Leeford Healthcare Ltd., LEO House, DugriDhadra Road, Shaheed Bhagat Singh Nagar, Ludhiana स्थायी लेखा सं/ . PAN NO: ACBPK3657Q अपीलार्थी/ Appellant प्रत्यर्थी / Respondent Cross Objection No. 23/Chd/2024 In (आयकर अपील सं/ . ITA No. 549/Chd/2024) निर्धारण वर्ष / Assessment Year : 2

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Hitesh Bhakoo, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 271Section 271A

appeal. CO No. 24/CHD/2024 (Assessee) 3 1. That the Ld. CIT(A) has erred in dismissing the ground of appeal for levy of penalty u/s 271AAB being barred by limitation since the penalty order have been passed on 01.04.2022 in terms of clause 13(a) and 13(n) of notification ... appreciate that the order which was received before 31st of March 2022 by email on 31.03.2022, was without DIN Number and, thus, the levy of penalty u/s 271AAB is barred by limitation. 3. That respondent craves leave to add or amend the ground of cross objections before the appeal

Dy. Commissioner of Income Tax, Central Circle 3, Ludhiana, Punjab vs. Amit Kumar, Ludhiana

The appeal of the department is dismissed

ITA 549/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh27 May 2025AY 2018-19

Bench: SHRI RAJPAL .YADAV, VP &SHRI. KRINWANT SAHAY, AM आयकर अपील सं/ . ITA No. 549/Chd/2024 निर्धारण वर्ष / Assessment Year : 2018-19 Dy. Commissioner of Income Tax Central Circle 3, Ludhiana Punjab बनाम Amit Kumar C/o Leeford Healthcare Ltd., LEO House, DugriDhadra Road, Shaheed Bhagat Singh Nagar, Ludhiana स्थायी लेखा सं/ . PAN NO: ACBPK3657Q अपीलार्थी/Appellant प्रत्यर्थी / Respondent Cross Objection No. 23/Chd/2024 In (आयकर अपील सं/ . ITA No. 549/Chd/2024) निर्धारण वर्ष / Assessment Year : 20

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Hitesh Bhakoo, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 271Section 271A

appeal. CO No. 24/CHD/2024 (Assessee) 3 1. That the Ld. CIT(A) has erred in dismissing the ground of appeal for levy of penalty u/s 271AAB being barred by limitation since the penalty order have been passed on 01.04.2022 in terms of clause 13(a) and 13(n) of notification ... appreciate that the order which was received before 31st of March 2022 by email on 31.03.2022, was without DIN Number and, thus, the levy of penalty u/s 271AAB is barred by limitation. 3. That respondent craves leave to add or amend the ground of cross objections before the appeal

Intervalve Poonawalla Pvt. Ltd., Pune vs. DCIT, Central Circle 1(1), Pune

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

ITA 636/PUN/2025[2013-14]Status: DisposedITAT Pune27 May 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14 Intervalve Poonawalla Pvt. Ltd. Dcit, Central Circle 1(1), Fin Div. 16/B-1, Sarosh Bhavan, Pune Vs. 2Nd Floor, Dr. Ambedkar Road, Opp. Niv, Pune – 411001 Pan: Aaaci3917P (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Vishnu Bhutada Department By : Shri Ramnath P Murkunde Date Of Hearing : 14-05-2025 Date Of Pronouncement : 27-05-2025 O R D E R

For Appellant: Shri Nikhil S Pathak &For Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 143(3)Section 14ASection 263Section 271(1)(c)

made the disallowance of Rs.4,35,375/- u/s 14A and disallowed depreciation of Rs.89,42,896/- which is the subject matter for levy of penalty. 3. The assessee filed an appeal before the Ld. CIT(A) / NFAC and the Ld. CIT(A) / NFAC restricted the disallowance u/s 14A to Rs.1 ... with Rule 8D made the disallowance of Rs.4,40,375/- which was confirmed by the Ld. CIT(A) / NFAC. Therefore, the Assessing Officer levied the penalty on this amount. 4. Similarly, the Ld. CIT(A) / NFAC restricted the disallowance of depreciation on Helicopter to 1/7th of Rs.2

DCIT, Swargate Pune vs. Elica Pb Whirlpool Kitchen Appliances Private Limited, Pune

In the result, appeal of the Revenue in ITA No

ITA 407/PUN/2025[2014-15]Status: DisposedITAT Pune27 May 2025AY 2014-15

Bench: the Hon'ble Tribunal which may please be granted.” Submission of ld.AR : 2. Ld.AR for the assessee submitted that Quantum Addition has been deleted by ITAT for A.Y.2014-15 in Assessee's own case in

Section 250Section 271GSection 92CSection 92D

considering the facts of the case and submission of the assessee, I am fully satisfied that this is a fit case for levy of penalty u/s 271AA of the Income Tax Act, 1961. 1, therefore, direct the assessee to pay by way of penalty

DCIT, Swargate vs. Elica Pb Whirlpool Kitchen Appliances Private Limited, Pune

In the result, appeal of the Revenue in ITA No

ITA 383/PUN/2025[2014-15]Status: DisposedITAT Pune27 May 2025AY 2014-15

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 250Section 271GSection 92CSection 92D

considering the facts of the case and submission of the assessee, I am fully satisfied that this is a fit case for levy of penalty u/s 271AA of the Income Tax Act, 1961. 1, therefore, direct the assessee to pay by way of penalty

Smt Anjali Praphull Shivale, Pune vs. ACIT Circle2(3), Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1583/PUN/2024[2018-19]Status: DisposedITAT Pune27 May 2025AY 2018-19

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

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

find we have already restored the quantum addition to the file of the Assessing Officer for fresh adjudication. Therefore, the issue of levy of penalty u/s 271(1)(c) of the Act is also restored to his file for fresh adjudication after completion of the assessment. We hold and direct ... allowed for statistical purposes. 16. The assessee in the instant case has challenged the order of the Ld. CIT(A) in confirming the levy of penalty of Rs.58,88,200/- u/s 271(1)(c) of the Act. 17. After hearing both sides, we find the Ld. CIT(A) confirmed

Shri Praphull Kaluram Shivale, Pune vs. Central Circle 2(3), Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1582/PUN/2024[2014-15]Status: DisposedITAT Pune27 May 2025AY 2014-15

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

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

find we have already restored the quantum addition to the file of the Assessing Officer for fresh adjudication. Therefore, the issue of levy of penalty u/s 271(1)(c) of the Act is also restored to his file for fresh adjudication after completion of the assessment. We hold and direct ... allowed for statistical purposes. 16. The assessee in the instant case has challenged the order of the Ld. CIT(A) in confirming the levy of penalty of Rs.58,88,200/- u/s 271(1)(c) of the Act. 17. After hearing both sides, we find the Ld. CIT(A) confirmed

Shri Praphull Kaluram Shivale, Pune vs. Central Circle 2(3), Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1581/PUN/2024[2014-15]Status: DisposedITAT Pune27 May 2025AY 2014-15

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

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

find we have already restored the quantum addition to the file of the Assessing Officer for fresh adjudication. Therefore, the issue of levy of penalty u/s 271(1)(c) of the Act is also restored to his file for fresh adjudication after completion of the assessment. We hold and direct ... allowed for statistical purposes. 16. The assessee in the instant case has challenged the order of the Ld. CIT(A) in confirming the levy of penalty of Rs.58,88,200/- u/s 271(1)(c) of the Act. 17. After hearing both sides, we find the Ld. CIT(A) confirmed

Shri Praphull Kaluram Shivale, Pune vs. Central Circle 2(4), Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1577/PUN/2024[2016-17]Status: DisposedITAT Pune27 May 2025AY 2016-17

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

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

find we have already restored the quantum addition to the file of the Assessing Officer for fresh adjudication. Therefore, the issue of levy of penalty u/s 271(1)(c) of the Act is also restored to his file for fresh adjudication after completion of the assessment. We hold and direct ... allowed for statistical purposes. 16. The assessee in the instant case has challenged the order of the Ld. CIT(A) in confirming the levy of penalty of Rs.58,88,200/- u/s 271(1)(c) of the Act. 17. After hearing both sides, we find the Ld. CIT(A) confirmed

Shri Praphull Kaluram Shivale, Pune vs. Central Circle 2(4), Pune

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1038/PUN/2024[2015-16]Status: DisposedITAT Pune27 May 2025AY 2015-16

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

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl CIT DR
Section 133ASection 143(2)Section 143(3)Section 147Section 148Section 271(1)(c)

find we have already restored the quantum addition to the file of the Assessing Officer for fresh adjudication. Therefore, the issue of levy of penalty u/s 271(1)(c) of the Act is also restored to his file for fresh adjudication after completion of the assessment. We hold and direct ... allowed for statistical purposes. 16. The assessee in the instant case has challenged the order of the Ld. CIT(A) in confirming the levy of penalty of Rs.58,88,200/- u/s 271(1)(c) of the Act. 17. After hearing both sides, we find the Ld. CIT(A) confirmed

Fun N Food Restaurant, Thane vs. ACIT, Central Circle-3, Thane

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

ITA 6856/MUM/2024[2019-20]Status: DisposedITAT Mumbai27 May 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2019-20

For Appellant: Shri Hitesh Shah, Ld. A.RFor Respondent: Ms. Kavitha Kaushik, Ld. Sr. D.R
Section 144Section 250Section 271(1)(c)Section 37(1)

Subsequently, the penalty proceedings were also initiated u/s 271(1)(c)/270A of the Act, which resulted into levy of penalty u/s 271(1)(c)/270A of the Act, to the tune of Rs.57,23,766/- @ 200% of the income escaped/total additions of Rs.77,50,405/- (Rs.64,52,870/- + Rs.12

Imrankhan Gulambhai Shaikh, Na vs. Arivs.National Faceless Center, Assessment Unit

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

ITA 334/SRT/2024[2018-19]Status: DisposedITAT Surat26 May 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

Section 271D

passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), confirming the levy of penalty under section 271D of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19. I.T.A No. 334/SRT/2024

Vadakkekarayil Ramakrishnan Nair Surendran Nair, Thodupuzha vs. Income Tax Officer, Thodupuzha

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

ITA 13/COCH/2025[2018-2019]Status: DisposedITAT Cochin26 May 2025AY 2018-2019

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Sreejith R., CAFor Respondent: Smt.Leena Lal, Sr.AR
Section 271BSection 273B

Order No.ITBA/NFAC/S/250/2024- 25/1070655447(1) and relates to the assessment year 2018- 2019. 2. The solitary issue involved in this appeal is levy of penalty u/s.271B of the Act. The department has levied the penalty of Rs.1,50,000 on the ground that the assessee failed to submit the audit

Dudhsagar Research and Development Association, Mehsana vs. The DCIT(E) Circle-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1048/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad26 May 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & Shri ParinFor Respondent: Shri V Nandakumar, CIT DR
Section 271(1)(c)

grounds are dismissed.” 5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(A) confirming the levy of penalty under Section 271(1)(c) of the Act. Before us, the Counsel for the assessee submitted that admittedly in this case the ITAT had decided ... this issue against the assessee in quantum proceedings. However, this is by itself should not lead to automatic levy of penalty for furnishing inaccurate particulars of income when the full details with regards to these receipts as “corpus donation” have been submitted by the assessee during the course of assessment

Silicon Jewel Industries Pvt. Ltd., Ahmedabad vs. The CIT (A)-8, Ahmedabad

In the result, all appeals filed by the assessee are allowed for statistical purposes

ITA 617/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad26 May 2025AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri Parimalsinh B. Parmar, ARsFor Respondent: Smt. Trupti Patel, Sr. DR
Section 147Section 234ASection 271(1)(c)Section 68Section 69C

related to additions confirmed by Ld. CIT(A), with respect to quantum additions whereas ITA Nos. 586 & 617/Ahd/2019 relate to appeals against the levy of penalty confirmed by Ld. CIT(A) with respect to the additions ITA Nos. 421&422/Ahd/2019 & 586&617/Ahd/2019 Silicon Jewel Industries Pvt. Ltd. vs. ITO Asst.Years ... passing the quantum order. 2. The learned CIT(A) has erred both in law and on the facts of the case in levying the penalty of Rs.96,362/- levied u/s 271(1)(c) of the Act. 3. In any case, the impugned penalty order is barred by limitation and thus