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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

Raigaon Sugar and Power Limited, Karad vs. ITO, Ward-1, Cir-Satara, Satara

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 3176/PUN/2025[2018-19]Status: DisposedITAT Pune18 Feb 2026AY 2018-19

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri Pramod Shahakar, JCIT
Section 142(1)Section 144Section 250Section 270A

penalty at ₹ 11,27,344/- @ 50% of the tax payable on under-reported income. 6. Aggrieved with the quantum addition as well as levy of penalty, assessee preferred appeal before the Ld.CIT(A), but with huge delay of 1340 & 1088 days. The reasons for the said delay have been stated

Ashutosh Dubey, Kanjurmarg vs. DCIT Circle-8, Pune

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

ITA 2215/PUN/2025[2019-20]Status: DisposedITAT Pune18 Feb 2026AY 2019-20

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2215/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Ashutosh Dubey, V Income Tax Officer, Tower 8, Flat No.3201, Runwal S Circle-8, Pune. Forest, Lbs Road, Kanjurmarg West, Maharashtra – 400078 Pan: Ajppd0173M Appellant/ Assessee Respondent /Revenue Assessee By Shri Amar Pandey (Virtual) Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 20/01/2026 Date Of Pronouncement 18/02/2026

Section 139Section 139(1)Section 147Section 148Section 246ASection 250Section 270ASection 274(2)Section 5

cause, has committed default by under reporting of income as defined u/s 270A of the Act. As such, this is fit case for levy of penalty u/s 270A of the act. The amount of Rs.32,23,520/- represents the under reported income of the assessee within the meaning of section ... assessee for the income offered towards capital gains derived from the transfer of property. Therefore, the A.O. ought not to have levied the penalty under Section 270A of the Act, for underreporting of income. The Ld. CIT(A),without appreciating relevant facts, simply sustained the penalty levied

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 1301/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention ... assessable to tax and therefore, the provisions of sec.269SS would not be applicable in the case of the assessee. Thereafter, the JCIT levied the penalty u/sec.271D of the Act vide order dated 23.06.2021 which was challenged by the assessee before the learned CIT(A) but could not succeed. 11. Before

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle 2(4), Hyderabad

ITA 1300/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Feb 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention ... assessable to tax and therefore, the provisions of sec.269SS would not be applicable in the case of the assessee. Thereafter, the JCIT levied the penalty u/sec.271D of the Act vide order dated 23.06.2021 which was challenged by the assessee before the learned CIT(A) but could not succeed. 11. Before

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 973/HYD/2024[2020-21]Status: DisposedITAT Hyderabad18 Feb 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention ... assessable to tax and therefore, the provisions of sec.269SS would not be applicable in the case of the assessee. Thereafter, the JCIT levied the penalty u/sec.271D of the Act vide order dated 23.06.2021 which was challenged by the assessee before the learned CIT(A) but could not succeed. 11. Before

Ravi Rishi Educational Society, Hyderabad vs. DCIT., Central Circle-2(4), Hyderabad

ITA 972/HYD/2024[2019-20]Status: DisposedITAT Hyderabad18 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita Nos.972 & 973/Hyd/2024

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 154Section 250Section 271D

therefore, is deserved to be quashed. 5. The Ld. CIT(A) failed to consider that the initiation and levy of penalty u/s 271D of the Act is not sustainable as the AO has not recorded his satisfaction for initiation of penalty proceedings u/s 271D of the Act in contravention ... assessable to tax and therefore, the provisions of sec.269SS would not be applicable in the case of the assessee. Thereafter, the JCIT levied the penalty u/sec.271D of the Act vide order dated 23.06.2021 which was challenged by the assessee before the learned CIT(A) but could not succeed. 11. Before

Uma Maheswari, Chennai vs. ACIT, Ncc-7(1), Chennai

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

ITA 2858/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.D. Anand, AdvocateFor Respondent: Mr.K. Iliayaraja, Addl.CIT
Section 115BSection 139(1)Section 147Section 148Section 271ASection 69A

Section 115BBE of the Act itself can’t be validly applied for AY 2017-18, the statutory computation Uma Maheswari :: 4 :: mechanism for levy of penalty u/s.271AAC of the Act fails. Be that as it may, we are not inclined to answer the legal issue and leave it open, since

M/S. R R Industries Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

ITA 2743/CHNY/2025[2010-11]Status: DisposedITAT Chennai18 Feb 2026AY 2010-11

Bench: Shri Aby T. Varkey & Ms. Padmavathy. Sआयकर अपील सं./Ita Nos.2741 To 2743/Chny/2025 निर्धारणवर्ष/Assessment Year: 2008-09 To 2010-11 M/S. Rr Industries Ltd., No.94/95, Thiru Vi Ka Industrial Estate, Guindy, Chennai-600 032. [Pan: Aaacr 3594 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Dcit, Central Circle-1(4), Chennai. (प्रत्यर्थी/Respondent) : Mr.M.K. Rangaswamy, Ca : Ms.R. Anitha, Addl.Cit : 11.02.2026 : 18.02.2026 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), (Hereinafter In Short 'The Ld.Cit(A)'), Chennai-18, Dated 07.08.2025, For The Assessment Year (Hereinafter In Short 'Ay') 2008-09 To 2010-11 Confirming The Penalty- Imposed U/S.271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act'). :: 2 ::

Section 10ASection 143(3)Section 153CSection 271(1)(c)Section 274

that the AO has not struck down the limbs/faults which are not applicable in the facts of the assessee's case for levy of penalty. In other words, the AO erred in imposing penalty u/s.271(1)(c) of the Act, without specifically mentioning in the impugned notice u/s.274 r.w.s

M/S. R R Industries Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

ITA 2742/CHNY/2025[2009-10]Status: DisposedITAT Chennai18 Feb 2026AY 2009-10

Bench: Shri Aby T. Varkey & Ms. Padmavathy. Sआयकर अपील सं./Ita Nos.2741 To 2743/Chny/2025 निर्धारणवर्ष/Assessment Year: 2008-09 To 2010-11 M/S. Rr Industries Ltd., No.94/95, Thiru Vi Ka Industrial Estate, Guindy, Chennai-600 032. [Pan: Aaacr 3594 H] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से / Respondent By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. The Dcit, Central Circle-1(4), Chennai. (प्रत्यर्थी/Respondent) : Mr.M.K. Rangaswamy, Ca : Ms.R. Anitha, Addl.Cit : 11.02.2026 : 18.02.2026 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), (Hereinafter In Short `The Ld.Cit(A)'), Chennai-18, Dated 07.08.2025, For The Assessment Year (Hereinafter In Short `Ay') 2008-09 To 2010-11 Confirming The Penalty- Imposed U/S.271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act'). :: 2 ::

Section 10ASection 143(3)Section 153CSection 2Section 271(1)(c)Section 274

pointed out that the AO has not struck down the limbs/faults which are not applicable in the assessee's case for levy of penalty. In other words, the AO erred in imposing penalty u/s.271(1)(c) of the Act, without specifically mentioning in the impugned notice u/s.274 r.w.s

M/S. R R Industries Ltd., Chennai vs. DCIT, Central Circle-1(4), Chennai

In the result, appeals filed by the assessee are allowed

ITA 2741/CHNY/2025[2008-09]Status: DisposedITAT Chennai18 Feb 2026AY 2008-09

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Mr.M.K. Rangaswamy, CAFor Respondent: Ms.R. Anitha, Addl.CIT
Section 10ASection 143(3)Section 153CSection 271(1)(c)Section 274

that the AO has not struck down the limbs/faults which are not applicable in the facts of the assessee’s case for levy of penalty. In other words, the AO erred in imposing penalty u/s.271(1)(c) of the Act, without specifically mentioning in the impugned notice u/s.274 r.w.s ... held such notices to be bad in law for not specifying the specific fault for which the assessee was being proceeded against for levy of penalty. And such ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 11 :: actions of the Tribunal has been upheld

Income Tax Officer-41.2.2, Mumbai vs. In Coach Builders, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 7993/MUM/2025[2009-10]Status: DisposedITAT Mumbai18 Feb 2026AY 2009-10

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailincome Tax Officer, Ward – 41(2)(2) Room No.834, 8Th Floor, Kautilya Bhawan, Bandra Kurla Complex, Mumbai - 400051 ............... Appellant Pan: Aaafi5110R V/S In Coach Builders, Plot No.1A, L.B.S Marg, Vikhroli (W), ……………… Respondent Mumbai- 400083

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, Sr. DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69

separately. After considering the submissions of the assessee, the AO vide order dated 05.03.2018 passed under section 271(1)(c) of the Act levied a penalty of Rs. 2,12,851/-. The learned CIT(A), vide impugned order, allowed the appeal filed by the assessee and deleted the penalty levied ... Court in CIT v/s Subhash Trading Co. Ltd., reported in [1996] 221 ITR 110 (Guj.) has taken a similar view in respect of levy of penalty under section 271(1)(c) of the Act on estimated additions. Therefore, it is evident that the issue about the justification for the imposition

Siddharth Agarwal, Udaipur vs. ACIT, Circle-2, Udaipur

In the result, the appeal of the assessee is allowed

ITA 647/JODH/2024[2015-16]Status: DisposedITAT Jodhpur17 Feb 2026AY 2015-16

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blesiddharth Agarwal Assistant Commissioner Of 28, Polo Ground, Income Tax, Cpc, Tds Udaipur - 313001 Udaipur Pan No. Akgpa 4183 N Assessee By Shri Shrawan Kumar Gupta, Advocate (Virtual) Revenue By Smt. Runi Pal – Cit-Dr (Virtual) Date Of Hearing 28.01.2026. Date Of Pronouncement 17.02.2026. Order Dr. Mitha Lal Meena, A.M.: This Appeal Is Filed By Assessee Against The Order Of Ld. Commissioner Of Income Tax, Appeal [Hereinafter Referred To As Cit(A)] Udaipur – 2 Dated 10.06.2024 With Respect To Assessment Year 2015-16 Challenging Therein The Sustaining The Levy Of Fee U/S 234A Of The Act By The Ao By View Of Rectification Order Dated 12.06.2022 Passed U/S 154 Of The Income Tax Act, 1961 Amounting To Rs. 28,600/- & Interest Of Rs. 16,016/- Totalling To Rs. 44,616/-, Although The Amended Law Was Not Applicable For The Year Under Consideration Because It Was Applicable Only With Effect From 01.06.2015. Asst. Year: 2015-16 2 2. At The Outset, The Ld. Counsel For The Assessee Submitted That The Appellant Assessee Filed A Rectification Application U/S 154 Of The Act Before The Acit, Cpc-Tds, Vaishali Ghajiabad For Tds In Form 27Q For Financial Year 2014- 15 With Respect To Quarter 4, Subsequently Rectification Order Was Passed On 12.06.2020 Determining Late Filing Fee/Penalty Of Rs. 28,600/- U/S 234A & Interest Of Rs. 16,016/- U/S 220 Of The Income Tax Act, 1961 Which Has Been Confirmed By Ld. Cit(A). Ignoring The Fact That Ao Did Not Have Power To Change Fee U/S 234E While Processing Tds Returns & Hence In Absence Of Enabling Provisions, Levy Of Fee Could Not Be Deducted In The Course Of Intimation Issued U/S 200A Prior To 01.06.2015. The Ld. Ar Prayed For Deleting The Fee & Interest Levied By The Acit, Cpc.

Section 154Section 200ASection 220Section 234ASection 234E

Having heard both the sides and perusal of record, we find that the Ld. CIT(A) failed to appreciate the fact that levy of penalty u/s 234E in the intimation order passed u/s 200A for Assessment Year 2015-16 with respect to it, TDS statement filed in Form

Sangeeta Golchha, Raipur vs. ITO-4(1), Raipur

In the result, appeal of the assessee is allowed

ITA 788/RPR/2025[2014-15]Status: DisposedITAT Raipur17 Feb 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.788/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Sangeeta Golchha 9/532, Behind Mahavir Bhawan, Budhapara, Raipur-492 001 (C.G.) Pan: Adcpg6259Q

For Appellant: Shri R.B Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 10(38)Section 271(1)(c)

under the said provisions. It is a matter of common knowledge that the assessment proceeding and penalty proceedings are two separate process altogether. Levy of penalty is not 4 Sangeeta Golchha Vs. ITO-4(1), Raipur (C.G.) automatic as a result of any outcome from the assessment. That

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2616/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

accordingly, dismissed the appeal of the assesee without going into the merits of the case. Consequently, Ld. CIT(A) also upheld a levy of penalty under Sectio271AAC(1) of the Act and under Section 270A of the Act. 25. In our considered view, looking into the substantial amount of additions

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

accordingly, dismissed the appeal of the assesee without going into the merits of the case. Consequently, Ld. CIT(A) also upheld a levy of penalty under Sectio271AAC(1) of the Act and under Section 270A of the Act. 25. In our considered view, looking into the substantial amount of additions

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2614/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

accordingly, dismissed the appeal of the assesee without going into the merits of the case. Consequently, Ld. CIT(A) also upheld a levy of penalty under Sectio271AAC(1) of the Act and under Section 270A of the Act. 25. In our considered view, looking into the substantial amount of additions

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2613/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

accordingly, dismissed the appeal of the assesee without going into the merits of the case. Consequently, Ld. CIT(A) also upheld a levy of penalty under Sectio271AAC(1) of the Act and under Section 270A of the Act. 25. In our considered view, looking into the substantial amount of additions

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2612/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

accordingly, dismissed the appeal of the assesee without going into the merits of the case. Consequently, Ld. CIT(A) also upheld a levy of penalty under Sectio271AAC(1) of the Act and under Section 270A of the Act. 25. In our considered view, looking into the substantial amount of additions

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT-2(3)(1), Mumbai

ITA 7704/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

interest expenditure. 2.3 The Appellant therefore prays that the aforesaid addition be deleted.” I.T.A. No. 7704/Mum/2025 (Penalty Appeal) 1. GROUND NO. 1: LEVY OF PENALTY UNDER SECTION 271(1)(C) OF THE ACT IS BAD IN LAW: 1.1. On the facts and in the circumstances of the case ... relying on the decision of the Ld. CIT(A) in the quantum appeal. 1.3. The Id. CIT(A) further erred in confirming the levy of penalty u/s. 271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account

Spice of Life Hotels and Estates Private Limited, Mumbai vs. DCIT- 2(3)(1), Mumbai

ITA 7703/MUM/2025[2014-15]Status: DisposedITAT Mumbai17 Feb 2026AY 2014-15

Bench: Smt. Beeba Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi &For Respondent: Assessee by
Section 143(3)Section 147Section 148Section 14ASection 271(1)(C)Section 271(1)(c)

interest expenditure. 2.3 The Appellant therefore prays that the aforesaid addition be deleted.” I.T.A. No. 7704/Mum/2025 (Penalty Appeal) 1. GROUND NO. 1: LEVY OF PENALTY UNDER SECTION 271(1)(C) OF THE ACT IS BAD IN LAW: 1.1. On the facts and in the circumstances of the case ... relying on the decision of the Ld. CIT(A) in the quantum appeal. 1.3. The Id. CIT(A) further erred in confirming the levy of penalty u/s. 271(1)(c) for allegedly furnishing inaccurate particulars of income whereas the levy of penalty by the Id. AO was on account