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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

M/S River Valley Flour Mills Pvt Ltd, Patna vs. ACIT, Central Circle-1, Patna

In the result, the appeal of the assessee is allowed

ITA 14/PAT/2025[2015-16]Status: DisposedITAT Patna10 Mar 2025AY 2015-16

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

For Appellant: Shri S.K. Tulsiyan, ARFor Respondent: Shri Ashwani Kr. Singal, DR
Section 132(1)Section 132(4)Section 142(1)Section 143(2)Section 153ASection 271A

only issue raised in various grounds of appeal is against the order of Id. CIT (A), Patna-3, upholding the levy of penalty u/s 271AAB of the Act by the Id. AO, where the Id. AO has not recorded any satisfaction about the undisclosed income or undisclosed books of accounts ... documents, money, bullion, jewellery or valuable article or thing even during the course of assessment or levy of penalty. 03. The facts in brief are that the assessee was subjected to search action u/s 132(1) of the Act on 17.08.2014, covering the residential and business premises of Gupta Nutrition

Sh. Trilok Chand Sain, Dausa vs. ITO, Ward-1(2), Alwar

ITA 1266/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C Parwal, FCAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 147Section 148Section 148ASection 271(1)(c)

1266/JP/2024, the assessee has taken following grounds of appeal: “The Ld. CIT(A), NFAC has erred on facts & in law in confirming the levy of penalty of Rs. 13,13,327/- u/s 271(1)(c) of IT Act, 1961. 2. The assessee craves to amend, alter and modify

Sh. Trilok Chand Sain, Dausa vs. ITO, Ward-1(2), Alwar

ITA 1265/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C Parwal, FCAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 147Section 148Section 148ASection 271(1)(c)

1266/JP/2024, the assessee has taken following grounds of appeal: “The Ld. CIT(A), NFAC has erred on facts & in law in confirming the levy of penalty of Rs. 13,13,327/- u/s 271(1)(c) of IT Act, 1961. 2. The assessee craves to amend, alter and modify

Ravi Pichaya, Nashik vs. Assistant Commissioner of Income Tax

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

ITA 73/PUN/2017[2008-09]Status: DisposedITAT Pune10 Mar 2025AY 2008-09

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Basavaraj Hiremath
Section 147Section 148Section 2(22)(e)Section 234A

nature of loan nor any interest have been charged by the Company from the appellant. The Hon'ble Tribunal has upheld the levy of penalty under section 271(1)(c) on the addition of deemed dividend in its order ITA No.7733/Mum/2010, Α.Υ. 2003-04 dated 05/02/2014. 5.16 The reliance

Ravi Pichaya, Director in Hextech Engineers India Pvt.Ltd, Nashik vs. Assistant Commissioner of Income-Tax, Circle - 1, Nashik

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

ITA 2205/PUN/2017[2009-10]Status: DisposedITAT Pune10 Mar 2025AY 2009-10

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Basavaraj Hiremath
Section 147Section 148Section 2(22)(e)Section 234A

nature of loan nor any interest have been charged by the Company from the appellant. The Hon'ble Tribunal has upheld the levy of penalty under section 271(1)(c) on the addition of deemed dividend in its order ITA No.7733/Mum/2010, Α.Υ. 2003-04 dated 05/02/2014. 5.16 The reliance

Samit Ashok Soniminde, Mumbai vs. Int Tax Commissioner of Income Tax-4(2)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 2763/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Mar 2025AY 2018-19

Bench: Hon’Ble Br Baskaranhon’Ble Shri Sandeep Gosainsamit Ashok Soniminde Vs. Ito – 4(2)(1) 2302 Solitaire, Adi Room No. 1704, 17Th Shankarachary Marg Floor Air India, Bldg, Powai, Mumbai – 400076. Nariman Point, Mumbai – 400021. Pan/Gir No. Aybps9158C (Applicant) (Respondent)

Section 144Section 263Section 270A

jurisdiction u/s.263 of the Act, is to initiate penalty proceedings u/s.270A of the Act. The provisions of Sec.270A of the Act, deals with levy of penalty for underreporting or misreporting of income. Therefore, in order to decide whether the PCIT is right in invoking the provisions of Sec.263 ... quashed the revision order passed by the PCIT u/s.263 of the Act. 9. We are also of the view that the proceedings for levy of penalty are proceedings independent and separate from the assessment proceedings, and even as per the facts of the present case, there are no findings recorded

Gurram Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

In the result, both the appeals filed by the assessee are dismissed

ITA 511/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2019-20

Bench: Shri K Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 510 & 511/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2019-20) Gurram Padmavathi, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahgpg4966L Visakhapatnam. (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri Gvn Hari, Ar प्रत्यधथी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 271ASection 69

orders of the Ld. AO the assessee preferred two appeals ie., one appeal against the quantum addition and the other appeal against the levy of penalty, before the Ld. CIT(A) with a delay of 457 days and 279 days respectively. Before the Ld. CIT(A), the assessee submitted that

Gurram Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

In the result, both the appeals filed by the assessee are dismissed

ITA 510/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2019-20

Bench: Shri K Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 510 & 511/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2019-20) Gurram Padmavathi, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahgpg4966L Visakhapatnam. (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri Gvn Hari, Ar प्रत्यधथी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 271ASection 69

orders of the Ld. AO the assessee preferred two appeals ie., one appeal against the quantum addition and the other appeal against the levy of penalty, before the Ld. CIT(A) with a delay of 457 days and 279 days respectively. Before the Ld. CIT(A), the assessee submitted that

Raghuram Hume Pipes Private Limited, Guntur vs. Assistant Commissioner of Income Tax, Circle-2(1), Guntur

In the result, appeal filed by the assessee is allowed

ITA 233/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2016-17

Bench: Shrik Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./ I.T.A.233/Viz/2024 (ननधधारण वर्ा/ Assessment Year:2016-17) Raghuram Hume Pipes Private Limited, Vs. Assistant Commissioner Of Guntur-522002. Income Tax, Pan: Aaccr6125N Circle-2(1), Guntur. (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri C. Subrahmanyam, Ca प्रत्यधथी की ओर से/ Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 274(2)

case and the provisions of law. 2. That the Ld. CIT(A) erred in upholding the actions of the AO in levying the penalty U/s. 271(1)(c) of the Act despite there being no concealment of income or furnishing of inaccurate particulars the essential ingredients required to be established ... before levying such penalty. 3. The Ld. CIT(A) ought to have acknowledged that the assessee company had offered additional income in the return of income filed in response to notice U/s. 148 of the Act and this return of income was duly accepted by the AO. Therefore, the levy

Kapil Taneja, Jaipur vs. ACIT Circle 3, Jaipur

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

ITA 13/JPR/2025[2016-17]Status: DisposedITAT Jaipur07 Mar 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 68

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

Sujan Infrastructure Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Central Circle-1(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 474/AHD/2024[2006-07]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2006-07

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr Advocate &For Respondent: Shri Yogesh Mishra, Sr. DR
Section 132(1)Section 250Section 271(1)(c)

learned CIT(A) has erred in law and on facts of the case in confirming levy of penalty of Rs.12,00,659/- u/s 271(1)(c) of the Act Sujan Infrastructure Pvt Ltd Vs. DCIT Asst. Year : 2006-07 - 2– in respect of addition of Rs.35,67,018/- made ... assessee has furnished inaccurate particulars of income to the tune of Rs.39,31,296/- and therefore this is a fit case for levy of penalty u/s 271(1)(c)’. To conclude, the Assessing Officer levied penalty holding that ‘the assessee has committed default

Deputy Commissioner of Income Tax, Vadodara vs. Gujarat State Electricity Corporation Limited, Vadodara

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

ITA 1289/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2011-12

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 271Section 271(1)(c)

ACIT reported in (2012) 22 taxmann.com 155. However the above explanation was not found to be satisfied and thereby the Assessing Officer levied a penalty of Rs.16 crore u/s. 271(1)(c) of the Act for furnishing inaccurate particulars of income. 4. Aggrieved against the penalty order, the assessee filed ... cases prior to 1-4-2016, if any adjustment is made in the income computed for the purpose of MAT, then the levy of penalty u/s 271(1)(c) of the Act, will depend on the nature of adjustment 6. The above settled position is to be followed in respect

Xcellon Education Limited, Ahmedabad vs. Addl. CIT, TDS, Ahmedabad

The appeal of the assessee is allowed

ITA 2681/AHD/2017[2016-2017]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2016-2017

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 133ASection 201Section 201(1)Section 250(6)Section 271CSection 272A(2)(g)

same assessee and pertain to two different assessment years i.e. Asst.Year 2015-16 and 2016-17 with the issues involved relating to levy of penalty under section 272A(2)(g) and section 271C of the Income Tax Act, 1961 ("the Act" for short). All the appeals arise from the order ... levied by the AO for both the assessment years. 2. While the appeal in IT No.2679/Ahd/2017 and 2681/Ahd/2017 pertains to the issue of levy of penalty under section 271C of the Act ITA No.2678 to 2681/Ahd/2017 (4 Appeals) 2 for the Asst.Year 2015-16 and 2016-17 respectively, the appeal

Xcellon Education Limited, Ahmedabad vs. Addl. CIT, TDS, Ahmedabad

The appeal of the assessee is allowed

ITA 2680/AHD/2017[2016-2017]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2016-2017

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 133ASection 201Section 201(1)Section 250(6)Section 271CSection 272A(2)(g)

same assessee and pertain to two different assessment years i.e. Asst.Year 2015-16 and 2016-17 with the issues involved relating to levy of penalty under section 272A(2)(g) and section 271C of the Income Tax Act, 1961 ("the Act" for short). All the appeals arise from the order ... levied by the AO for both the assessment years. 2. While the appeal in IT No.2679/Ahd/2017 and 2681/Ahd/2017 pertains to the issue of levy of penalty under section 271C of the Act ITA No.2678 to 2681/Ahd/2017 (4 Appeals) 2 for the Asst.Year 2015-16 and 2016-17 respectively, the appeal

Xcellon Education Limited, Ahmedabad vs. Addl. CIT, TDS, Ahmedabad

The appeal of the assessee is allowed

ITA 2679/AHD/2017[2015-2016]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2015-2016

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 133ASection 201Section 201(1)Section 250(6)Section 271CSection 272A(2)(g)

same assessee and pertain to two different assessment years i.e. Asst.Year 2015-16 and 2016-17 with the issues involved relating to levy of penalty under section 272A(2)(g) and section 271C of the Income Tax Act, 1961 ("the Act" for short). All the appeals arise from the order ... levied by the AO for both the assessment years. 2. While the appeal in IT No.2679/Ahd/2017 and 2681/Ahd/2017 pertains to the issue of levy of penalty under section 271C of the Act ITA No.2678 to 2681/Ahd/2017 (4 Appeals) 2 for the Asst.Year 2015-16 and 2016-17 respectively, the appeal

Xcellon Education Limited, Ahmedabad vs. Addl. CIT, TDS, Ahmedabad

The appeal of the assessee is allowed

ITA 2678/AHD/2017[2015-2016]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2015-2016

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

Section 133ASection 201Section 201(1)Section 250(6)Section 271CSection 272A(2)(g)

same assessee and pertain to two different assessment years i.e. Asst.Year 2015-16 and 2016-17 with the issues involved relating to levy of penalty under section 272A(2)(g) and section 271C of the Income Tax Act, 1961 ("the Act" for short). All the appeals arise from the order ... levied by the AO for both the assessment years. 2. While the appeal in IT No.2679/Ahd/2017 and 2681/Ahd/2017 pertains to the issue of levy of penalty under section 271C of the Act ITA No.2678 to 2681/Ahd/2017 (4 Appeals) 2 for the Asst.Year 2015-16 and 2016-17 respectively, the appeal

Income Tax Officer Exemption Ward, Tirupati vs. Sree Ssv Gate Society, Tirupati

In the result, appeal of the Revenue is dismissed and C

ITA 1214/HYD/2024[2016-17]Status: DisposedITAT Hyderabad07 Mar 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1214/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Income Tax Officer Vs. Sree Ssv Gate Society Exemption Ward Tirupati Tirupati Pan:Aagts4803D (Appellant) (Respondent) C.O No.1/Hyd/2025 आ.अपी.सं /Ita No.1214/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Sree Ssv Gate Society Vs. Income Tax Officer Tirupati Exemption Ward Pan:Aagts4803D Tirupati (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr सुनवाई की तारीख/Date Of Hearing: 05/03/2025 घोषणा की तारीख/Pronouncement: 07/03/2025 आदेश/Order

For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: : Shri Srinath Sadanala, DR
Section 269SSection 269sSection 271DSection 274

learned AR has submitted that once the transaction does not fall in the ambit of provisions of section 269SS, then the question of levy of penalty u/s 271D does not arise. Page 3 of 9 ITA No 1214 of 2024 SREE SSV Gate Society 6. On the other hand ... received by the assessee. Once this transaction does not fall in the ambit of provisions of section 269SS, then the question of levy of penalty u/s 271D does not arise. Accordingly, we hold that the penalty levied by the Assessing Officer u/s 271D of the Act is not sustainable

Prakashchand Jain, Chennai vs. DCIT, CC2(3), Chennai

In the result, appeal filed by the assessee is allowed

ITA 68/CHNY/2024[2017-18]Status: DisposedITAT Chennai07 Mar 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.68/Chny/2024 िनधा रण वष /Assessment Year: 2017-18 Prakashchand Jain, The Dy. Commissioner Of V. 39 & 40 Bakers Street, Income Tax, Choolai, Chennai – 600 112. Central Circle-2(3), Chennai. [Pan: Ahhpp 1690D] (अपीलाथ$/Appellant) (%&थ$/Respondent) अपीलाथ$कीओरसे/ Appellant By : Mr. N. Arjun Raj, Advocate %&थ$कीओरसे /Respondent By Shri R. Clement Ramesh : Kumar, Cit सुनवाईकीतारीख/Date Of Hearing : 10.12.2024 घोषणाकीतारीख /Date Of Pronouncement 07.03.2025 :

For Appellant: Mr. N. Arjun Raj, Advocate
Section 132Section 153Section 153ASection 270A

penalty levied by the AO u/s.270A of the Income Tax Act, 1961 (hereinafter referred to as "the Act”). 2. The brief facts regarding levy of penalty u/s.270A of the Act are that the assessee is a professional Doctor of M/s. Appollo Hospital and has (AY 2017-18) ::2 :: filed ... attracted in the facts of the case, to 70A of the Act has been attracted in the facts of the case, to deserve levy of penalty and deserve levy of penalty and how the ingredient of sub- -section (9) of Section 270A is satisfied. Section 270A is satisfied. Therefore, show

Hydro Power Development Corporation of Arunachal Pradesh Limited, Itanagar vs. A.C.I.T., Circle Tezpur, Tezpur

Appeals of the assessee are allowed for statistical purposes

ITA 72/GTY/2024[2012-13]Status: DisposedITAT Guwahati06 Mar 2025AY 2012-13

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 144Section 147Section 250Section 271(1)(c)

read with section 144 of the Act. Admittedly, this determination was done on an allegedly invalid return. Thereafter, the Ld. AO proceeded to levy of penalty of Rs. 39,08,542/- under Section 271(1)(c) of the Act. Here it needs to be mentioned that ... justice, the assessee deserves another chance to submit necessary details before the Ld. CIT(A) so that the facts and circumstances surrounding the levy of penalty under Section 271(1)(c) of the Act can be determined, one way or another. Accordingly, we set aside the order

Sumaiya Enterprise, Barpeta vs. ITO, Ward - Barpeta Road, Barpeta

ITA 202/GTY/2024[2018-19]Status: DisposedITAT Guwahati06 Mar 2025AY 2018-19

Bench: The Ld. Assessing Officer, Nor Any Return Of Income Was Filed. Thereafter, The Ld. Assessing Officer Proceeded To Add Rs. 1,15,71,000/- Under Section 69A & 69C Of The Act.

Section 147Section 271ASection 69ASection 69C

batch of 2 appeals pertaining to the same assessee. ITA No. 201/Gty/2024 pertains to the quantum matter and ITA No. 202/Gty/2024 challenges the levy of penalty under Section 271AAC(1) of the Income-tax Act, 1961 (hereafter “the Act”). For the sake of convenience, these two appeals are being disposed