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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

Poonam Gupta, Gwalior vs. Assistant Commissioner of Income Tax, Circle-1(1), Gwalior

Appeal of the assessee is allowed in above terms

ITA 215/AGR/2024[2006-07]Status: DisposedITAT Agra24 Apr 2025AY 2006-07

Bench: :Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2006-07

Section 132(1)Section 143(3)Section 153ASection 250(6)Section 271(1)(c)Section 68

parties, we find merit in the contention of the ld. Counsel for the assessee that it is not a fit case for levy of penalty u/s. 271(1)(c) of the Act. Undisputedly, the penalty has been levied on an addition of Rs.70,14,083/- made in the case ... which penalty was levied, it shows that the concealment is not final and the issue is debatable. Therefore, there is no case for levy of penalty. In the light of the same, we hold that the penalty levied in the 4 | P a g e present case being

Branch Manager State Bank of India, Regional Business Office, Administretive Office, Kanpur vs. ACIT (TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 491/LKW/2024[2017-18]Status: DisposedITAT Lucknow24 Apr 2025AY 2017-18

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,04,380/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before ... order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before the Ld. CIT (A) and without

Branch Manager State Bank of India, Regional Business Office, Administretive Office, Kanpur vs. ACIT (TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 490/LKW/2024[2016-17]Status: DisposedITAT Lucknow24 Apr 2025AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,04,380/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before ... order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before the Ld. CIT (A) and without

Branch Manager State Bank of India, Regional Business Office, Administretive Office, Kanpur vs. ACIT (TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 489/LKW/2024[2015-16]Status: DisposedITAT Lucknow24 Apr 2025AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,04,380/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before ... order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before the Ld. CIT (A) and without

State Bank of India, Overseas Branch, Kanpur vs. ACIT(TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 488/LKW/2024[2016-17]Status: DisposedITAT Lucknow24 Apr 2025AY 2016-17

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,04,380/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before ... order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before the Ld. CIT (A) and without

State Bank of India, Overseas Branch, Kanpur vs. ACIT(TDS), Kanpur

In the result, all the appeals of the assessee are dismissed

ITA 487/LKW/2024[2015-16]Status: DisposedITAT Lucknow24 Apr 2025AY 2015-16

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshra

Section 10(5)Section 250Section 271CSection 273B

order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1,04,380/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before ... order passed u/s 250 r. w. s 271C of the Act dated 10/06/2024 dismissing the appeal filed by the Appellant and confirming the levy of penalty of Rs.1/- by the Ld. CIT(A), without giving any justifiable reasoning and ignoring the submissions made before the Ld. CIT (A) and without

The Ahmedabad District Co.Op. Bank Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1108/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad24 Apr 2025AY 2020-21
For Appellant: Shri Sanjay R. Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 139(1)Section 143(3)Section 155(18)Section 270ASection 40

notified at the time of passing of order u/s.143(3) of the Act, the provisions of section 155(18) cannot be applied to levy the penalty u/s.270A of the Act. 5. The appellant reserves the right to add/alter or remove any of the above grounds of appeal. 6. During ... Finance Act, 2022, with retrospective effect from 01.04.2005, merely clarified the legal position and could not be invoked for levy of penalty on a claim made bona fide and supported by judicial rulings. The AR further pointed out that the deduction was voluntarily surrendered during assessment proceedings, vide letter dated

Sanghi Textiles Private Limited, Hyderabad vs. Income Tax Officer, Ward-3(1), Hyderabad

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

ITA 759/HYD/2024[2014-15]Status: DisposedITAT Hyderabad24 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P Murali Mohan RaoFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 144BSection 147Section 194ASection 194CSection 271BSection 44ASection 69B

Thus, he submitted that when the audit report was filed before framing of the assessment order by the Assessing Officer, then the levy of penalty u/s 271B is not justified. He further submitted that filing the audit report is only a procedural requirement and once the assessee has filed ... before the Assessing Officer as well as before the learned CIT(A) for delay in filing the audit report. Therefore, the authorities below levied the penalty u/sec.271B of the Act which is in accordance with the provisions of the Income Tax Act and as such, the same may please

Subrata Moitra, Durgapur vs. Commissioner of Income-Tax (Appeals), Delhi

In the result, the appeal of the assessee is allowed

ITA 1827/KOL/2024[2014-15]Status: DisposedITAT Kolkata24 Apr 2025AY 2014-15

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(3)Section 271(1)Section 271(1)(c)Section 274Section 40A(3)Section 68

scrutiny, an order u/s 143(3) of the Act was passed by assessing total income at Rs. 86,11,216/-. Penalty proceedings for levying of penalty u/s 271(1)(c) of the Act was initiated in the assessment order. In the notice u/s 274 read with Section ... holding that the case law is not applicable in the instant case. In view of the same, we confirm the levy of penalty u/s 271(1)( c) of the Act by AO for furnishing inaccurate particulars of income. 8. We have gone through the copy of penalty of notice

Anjali Neeraj Hardikar, Pune vs. PCIT (Central), Mumbai-3, Mumbai

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

ITA 2704/MUM/2024[2011-12]Status: DisposedITAT Mumbai24 Apr 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankaranjali Neeraj Hardikar Vs. Pcit (Central) E/3, Vibhawari Apartments, 1901, 19Th Floor, Air Sahwas Society, Lane No.1, India Bldg, Nariman Karve Nagar – 411052. Point, Maharashtra – 400021. Pan/Gir No. Aafph0320K (Applicant) (Respondent)

Section 142(1)Section 143(3)Section 263Section 271(1)(c)Section 274Section 80G

penalty u/s 80GGC was deleted. 10. Be that as it may, the order of coordinate Bench is not relevant with regard to non levy of penalty with regard to other three issues as in the said order, discussion is only with regard to the claim of wrong deduction u/s 80GGC ... Personal expenses separately for each issue for furnishing inaccurate particulars of income.” 13. However even before us, there is no justification for not levying the penalty in respect of three issues. It is worth mentioning here that the Hon’ble High Court of Allahabad in the case

Opulent Trading and Investment Private Limited, Cp Tank Road vs. ITO-10(3)-2, Mumbai, Aayakar Bhavan, Maharishi Karve Road

In the result, appeal of the assessee is allowed

ITA 117/MUM/2024[2013-14]Status: DisposedITAT Mumbai24 Apr 2025AY 2013-14
Section 131Section 132(4)Section 133(6)Section 143(3)Section 271(1)(c)

Accordingly, the disallowance of interest paid is deleted. 17. In the result, appeal of the assessee is allowed. 18. In so far as levy of penalty, the same have been levied on addition of Rs.50,00,000/-by the ld. AO. Since we have deleted the quantum addition, therefore

Opulent Trading and Investment Private Limited, Cp Tank Road vs. ITO-10(3)-2, Mumbai, Aayakar Bhavan, Maharishi Karve Road

In the result, appeal of the assessee is allowed

ITA 115/MUM/2024[2013-14]Status: DisposedITAT Mumbai24 Apr 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 131Section 132(4)Section 133(6)Section 143(3)Section 271(1)(c)

Accordingly, the disallowance of interest paid is deleted. 17. In the result, appeal of the assessee is allowed. 18. In so far as levy of penalty, the same have been levied on addition of Rs.50,00,000/-by the ld. AO. Since we have deleted the quantum addition, therefore

Opulent Trading and Investment Private Limited, Cp Tank Road vs. ITO-10(3)-2, Mumbai, Aayakar Bhavan, Maharishi Karve Road

In the result, appeal of the assessee is allowed

ITA 114/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Apr 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 131Section 132(4)Section 133(6)Section 143(3)Section 271(1)(c)

Accordingly, the disallowance of interest paid is deleted. 17. In the result, appeal of the assessee is allowed. 18. In so far as levy of penalty, the same have been levied on addition of Rs.50,00,000/-by the ld. AO. Since we have deleted the quantum addition, therefore

Nilima Agrawal, Raipur vs. Income Tax Officer, Ward-3(1), Raipur

In the result, appeal of the assessee is allowed

ITA 126/RPR/2025[2015-16]Status: DisposedITAT Raipur23 Apr 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.126/Rpr/2025 "नधा"रण वष" / Assessment Year : 2015-16 Nilima Agrawal E-5, Sector-1, Devendra Nagar, Raipur (C.G.)-492 001 Pan: Afepa5240B ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Ward-3(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri S.L Anuragi, CIT-DR
Section 271Section 271(1)(c)Section 274

further held that in absence of specific charge for initiation of penalty proceedings, the Tribunal rightly held that the levy of penalty u/s. 271(1)(c) of the Act in the case of the assessee was not valid. 5. That on similar facts and circumstances regarding ambiguity in the notice

Zenobia Phiroze Irani, Chennai vs. ITO, Ncw-3(3), Chennai

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

ITA 2913/CHNY/2024[2023-24]Status: DisposedITAT Chennai23 Apr 2025AY 2023-24

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.2913/Chny/2024, Assessment Years: 2023-24 Zenobia Phiroze Irani, Income Tax Officer, New No.7, Muthiah Street, Non-Corporate, Teynampet, Ward-3(3), Chennai-600 086. Chennai [Pan: Aaapi1704R] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri S.Sridhar, Advocate प्रत्यर्थी की ओर से /Revenue By : Smt.Samantha Mullamudi, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 27.03.2025 घोषणा की तारीख /Date Of Pronouncement : 23.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri S.Sridhar, AdvocateFor Respondent: Smt.Samantha Mullamudi, Addl.CIT
Section 234CSection 234F

appeal are regarding the levy of interest under section 234C of Rs.4,04,826/- for non-payment of advance tax as also the levy of penalty under section 234F of Rs.5000/- for ITA No.2913 /Chny/2024 belated filing of the return of income. It has been submitted that the revenue authorities

Seoyon E-Hwa Summit Automotive India Private Limited, Kancheepuram vs. Commissioner of Income-Tax (Appeals), Na

In the result, appeal filed by the assessee is allowed

ITA 2091/CHNY/2024[2009-10]Status: DisposedITAT Chennai23 Apr 2025AY 2009-10

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Lalit Kumar, CAFor Respondent: Dr.I. Roopa, Addl.CIT
Section 143(3)Section 271Section 271(1)(c)Section 37(1)Section 40A(3)Section 43A

first/original- assessment order (quantum) u/s 143(3) passed by the AO dated 05.02.2013, the AO didn’t record any satisfaction about levy of penalty u/s.271(1)(c) of the Act, which was challenged by the assessee before Ld CIT(A) & finally before this Tribunal; and the Tribunal vide order dated ... giving effect dated 31.12.2019 wherein he has reiterated the addition in respect of valuation of closing stock of Rs.1,08,42,289/- has levied total penalty u/s.271(1)(c) of the Act of Rs.11,17,80,905/- relating to all three (3) issues. 3. The main plea of the assessee

Rukshmani Dedhia, Legal Heir of Jayantilal Tokershi Dedhia, Mumbai vs. ITO Ward 2(2), Kalyan

In the result, appeal of the assessee is allowed

ITA 1103/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Apr 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

Section 271(1)(C)Section 271(1)(c)

passed by NFAC, Delhi in relation to the penalty proceedings u/s. 271(1)(c) for the A.Y.2015-16. 2. The assessee is aggrieved by levy of penalty of Rs.2,40,919/- u/s.271(1)(C). 2 Rukshmani Dedhia, Legal Heir of Jayantilal Tokershi Dedhia 3. The brief facts are that assessee ... assessee in line of the re-assessment proceedings for A.Y.2012-13. Similar facts are permeating in this appeal also. Now the ld. AO has levied the penalty for furnishing of inaccurate particulars of income instead of long term capital gain offered by the assessee should be taxed as short term capital

Hasmukh Khetshi Shah, Mumbai vs. ITO Circle 23(1), Mumbai

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

ITA 5932/MUM/2024[2010-11]Status: DisposedITAT Mumbai23 Apr 2025AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2010-11

For Appellant: Shri Ajay R. Singh, Ld. A.RFor Respondent: Shri Hemanshu Joshi, Ld. D.R
Section 131Section 143(1)Section 143(3)Section 147Section 148Section 250

broking firm choose not to appear, in spite of sending notice u/s 131 of the Act and the fact that the NSE has levied a penalty of Rs.2,20,000/- on the broker M/s. Pashupati Capital Services Pvt. Ltd. for indulging into client code modification in the assessment year under ... issue, wherein the client code modification was made by the broker and therefore penalty proceedings were initiated against the broker, which resulted into levy of penalty by the NSE and thus the then Ld. CIT(A) deleted the identical addition and the Tribunal, ultimately affirmed the deletion of identical addition

Jyoti Gupta, Agra vs. Income Tax Officer 2(1)(1) Agra, Agra

The appeal stand allowed

ITA 560/AGR/2024[2022-23]Status: DisposedITAT Agra22 Apr 2025AY 2022-23

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.560/Agr/2024 (िनधा"रणवष" / Assessment Year:2022-23) Ms. Jyoti Gupta Income-Tax Officer बनाम/ 25/52, Chhipitola, Chakkipat, Ward 2(1)(1), Agra. Vs. Agra. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bxxpg-3113-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Rajendra Sharma, Adv. – Ld. Ar " थ"कीओरसे/Respondent By : Sh. Shailender Shrivastava – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 21-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 22.04.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2022-23 Arises Out Of An Order Passed By Learned Commissioner Of Income Tax (Appeals), Nfac, Delhi [Cit(A)] On 21-11-2024 In The Matter Of A Penalty Levied By Ld. Ao U/S 272A(1)(D) For Rs.30000/- Vide Impugned Order Dated 25-06-2024. Having Heard Rival Submissions, The Appeal Is Disposed-Off As Under. 2. The Impugned Penalty Stem From The Fact That Ld. Ao Framed An Assessment On Best Judgment Basis Since The Notices Sent On Email Id Was Not Complied With. For The Said Lapse, Ld. Ao Imposed Impugned Penalty Which Got Confirmed In First Appeal. Aggrieved, The Assessee Is In Further Appeal Before Us.

For Appellant: Sh. Rajendra Sharma, Adv. – Ld. ARFor Respondent: Sh. Shailender Shrivastava – Ld. DR
Section 272A(1)(d)

Accordingly, the assessee could not comply with various notices. Under these circumstances, we would hold that it is not a fit case for levy of penalty. By deleting the same, we allow the appeal of the assessee. 4. The appeal stand allowed. Order pronounced u/r 34(4) of Income

S G Commercial, Jhansi vs. Joint Commissioner of Income Tax, Central Circle, Kanpur

Appeals stand allowed

ITA 371/AGR/2024[2018-19]Status: DisposedITAT Agra22 Apr 2025AY 2018-19

Bench: Hon’Ble Shri Satbeer Singh Godara, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.364/Agr/2024 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.365/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.368/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 4. आयकरअपीलसं./ Ita No.370/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19; Smc Bench) & 5. आयकरअपीलसं./ Ita No.366/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 6. आयकरअपीलसं./ Ita No.367/Agr/2024 (िनधा"रणवष" / Assessment Year: 2016-17) & 7. आयकरअपीलसं./ Ita No.369/Agr/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & 8. आयकरअपीलसं./ Ita No.371/Agr/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Acit (Central Circle) M/Ss G Commercial बनाम/ Vs. 452/2A, Cp Mission Compound Agra Jhansi Up 284003

For Appellant: Shri Suresh Gupta (CA) – Ld. ARFor Respondent: Shri Sukesh Kumar Jain – Ld. CIT DR
Section 132Section 142Section 143(1)Section 143(3)Section 145(3)Section 153ASection 153DSection 271DSection 40A(3)Section 68

decided in assessee’s favor for AY 2018-19. 9. The appeals listed at serial nos. 5 to 8 are penalty appeals assailing levy of penalty u/s 271D / 271E which emanates from respective assessment orders of Ld. AO for AYs 2016-17 to 2018-19. Since we have quashed assessments