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“deletion of penalty”

PenaltySection 271Section 271348 judgments

The decision most relied on for deletion of penalty is Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT (115 TTJ 419), cited in 292 judgments on BharatTax.

Leading authorities on deletion of penalty

Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT

115 TTJ 419 · 2008 · ITAT

citing judgments

Penalty under Section 272A(1)(d) for non-compliance with a notice issued under Section 142(1) is not leviable when the assessee demonstrates a reasonable cause for such non-compliance. The decision defines what constitutes 'reasonable cause' in this context.

Earthmoving Equipment Service Corporation v. DCIT 22(2), Mumbai

84 Taxmann.com 51 · 2017 · ITAT

citing judgments

A penalty levied under Section 271(1)(c) for concealment of income or furnishing inaccurate particulars cannot be deleted merely due to technical defects in the penalty notice, such as not ticking the specific default, if the assessee understood the charges.

K.C. Builders & Anr. v. ACIT

265 ITR 562 · 2004 · Supreme Court

citing judgments

When the addition made in the assessment order, on the basis of which a penalty for concealment under section 271(1)(c) is levied, is subsequently deleted, the penalty has no basis and must be cancelled.

CIT v. Subhash Trading Co. Ltd.

221 ITR 110 · 1996 · High Court

citing judgments

Penalty under Section 271(1)(c) of the Income Tax Act cannot be levied when an addition to income is based purely on an estimate, without concrete evidence proving concealment of income or furnishing of inaccurate particulars.

CIT v. Krishi Tyre Retreading and Rubber Industries

360 ITR 580 · 2014 · High Court

citing judgments

No penalty under section 271(1)(c) of the Income Tax Act is leviable when an addition to income is made purely on an estimation basis, absent concrete evidence of concealment or furnishing inaccurate particulars.

CIT v. Sangrur Vanaspati Mills Ltd.

303 ITR 53 · 2008 · High Court

citing judgments

Penalty under section 271(1)(c) of the Income-tax Act is not leviable when an addition to income is made purely on an estimated basis, without any concrete evidence of concealment or furnishing of inaccurate particulars.

Surajmal Parsuram Todi v. CIT

222 ITR 691 · 1996 · High Court

citing judgments

A penalty under Section 271B for failure to get accounts audited cannot be levied if a penalty under Section 271A has already been imposed for non-maintenance of books of account.

Commissioner of Income Tax v. Triumph International Finance (I) Ltd.

345 ITR 270 · 2012 · High Court

citing judgments

Transactions involving the receipt or repayment of loans or deposits solely through journal entries, without actual cash movement, contravene Sections 269SS and 269T. However, penalties under Sections 271D or 271E for such contraventions are not imposable if the assessee demonstrates a reasonable cause under Section 273B, particularly when no cash has passed between parties.

Judgments citing deletion of penalty

Deputy Commissioner of Income Tax, Central Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, both the appeals bearing ITA Nos 515 & 516/Mum/2025 filed by the revenue are dismissed

ITA 516/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Apr 2025AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidara

For Appellant: Ms.Priyanka Jain a/wFor Respondent: Shri Asif Karmali (SR DR)

Section 143(3)Section 250Section 270ASection 274Section 80

following grounds: - “1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the penalty of Rs. 2,49,34,501/- made u/s 270A of the Income Tax Act, 1961 for under reporting of income by overlooking the fact that ... respect of other assessment years involving identical facts, the Coordinate Bench of the ITAT, Mumbai had allowed the assessee’s appeal on merits, deleted the penalty imposed for the impugned year. This was despite the fact that the assessee had not challenged 4 ITA 515 and 516/Mum/2025 Jyothy Labs Limited

Deputy Commissioner of Income Tax, Central Circle-2(4), Mumbai vs. Jyothy Labs Limited, Mumbai

In the result, both the appeals bearing ITA Nos 515 & 516/Mum/2025 filed by the revenue are dismissed

ITA 515/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Apr 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidara

For Appellant: Ms.Priyanka Jain a/wFor Respondent: Shri Asif Karmali (SR DR)

Section 143(3)Section 250Section 270ASection 274Section 80

following grounds: - “1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the penalty of Rs. 2,49,34,501/- made u/s 270A of the Income Tax Act, 1961 for under reporting of income by overlooking the fact that ... respect of other assessment years involving identical facts, the Coordinate Bench of the ITAT, Mumbai had allowed the assessee’s appeal on merits, deleted the penalty imposed for the impugned year. This was despite the fact that the assessee had not challenged 4 ITA 515 and 516/Mum/2025 Jyothy Labs Limited

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5136/MUM/2024[2002-03]Status: DisposedITAT Mumbai29 Apr 2025AY 2002-03

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5134/MUM/2024[2003-04]Status: DisposedITAT Mumbai29 Apr 2025AY 2003-04

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5132/MUM/2024[2006-07]Status: DisposedITAT Mumbai29 Apr 2025AY 2006-07

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5131/MUM/2024[2007-08]Status: DisposedITAT Mumbai29 Apr 2025AY 2007-08

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5129/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Apr 2025AY 2011-12

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

DCIT 41 1 1, Mumbai vs. Satya Kim Yashpal, Mumbai

ITA 5120/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Apr 2025AY 2009-10

Bench: returning to India in the year 2001. JSY expired on 28/06/2017.

For Appellant: NoneFor Respondent: Dr. Kishor Dhule; Shri Bhangepatil

Section 143(3)Section 250Section 271(1)(c)

appeal preferred by the Assessee, against the above penalty order, the CIT(A) granted relief to the Assessee by deleting the penalty levied. 3.8. Being aggrieved by the above relief granted by the CIT(A), the Revenue has preferred the present appeals before this Tribunal. The Assessee has filed Cross ... Assessee computed @ 300% of the tax sought to be evaded. 8. In appeal preferred by the Assessee, the learned CIT(A) deleted the penalty observing that there can be no protective levy of penalty. We find that while holding as aforesaid the learned CIT(A) has placed reliance

Superfine Hotels Private Limited, Jaipur vs. Deputy Commissioner of Income Tax, Circle-6, Jaipur

In the result, appeal of the assessee is partly allowed

ITA 1502/JPR/2024[2015-16]Status: DisposedITAT Jaipur22 Apr 2025AY 2015-16

For Appellant: Shri S.L. Poddar, Adv. &For Respondent: Shri P.P. Meena, CIT

Section 250Section 271(1)(c)Section 35A

fully applicable to the facts of the case, the penalty levied deserved to be cancelled. The Hon'ble Tribunal is accordingly requested to delete the penalty imposed by the Learned Assessing Officer and confirmed by the Learned CIT(A). Ground No.3 In the facts and circumstances of the case ... KALA KENDRA HIGH COURT OF RAJASTHAN (2015) 273 CTR 0522 (Raj), (2014) 369 ITR 0132 (Raj) In our view, the Tribunal has rightly deleted the penalty for the reason that though the claim was disallowed by the AO, thereafter, partly allowed by the CIT(A) and further not pressed

ACIT-CC-1, Chandigarh vs. M/S Bajwa Developers Ltd., Kharar

ITA 344/CHANDI/2020[2012-13]Status: DisposedITAT Chandigarh22 Apr 2025AY 2012-13

Bench: The Cit(A)(Central), Gurgaon. The Ld. Cit(A) Vide Order, Dated 26.04.2019 Sustained The Penalty Of Rs. 1,58,68,413/-, Against That Order, The Assessee Has Filed This Appeal Before The 2

For Appellant: Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

Section 154Section 271Section 271ASection 274

Constructions Pvt.Ltd. Vs DCIT, as reported in 48 CCGH 0178, wherein the decision of Hon'ble Apex Court have been followed for deletion of penalty u/s 271 AAA. 9 iii). Chandigarh Bench of ITAT in the case of Sh. Satish Goyal in ITYA No.636/Chd/2016, wherein the decision ... Apex Court have been followed for deletion of penalty u/s 271AAA. iv). The judgment of Apex Court in the case of ACIT Vs Gebital Kanhaialal HUF, as reported in 348 ITR 561. 10. The Ld. Counsel also referred to the statement of Sh. Jarnail Singh Bajwa, as recorded during search

ACIT, CC-1, Chandigarh vs. M/S Bajwa Developers Ltd., Kharar

ITA 343/CHANDI/2020[2012-13]Status: DisposedITAT Chandigarh22 Apr 2025AY 2012-13

Bench: The Cit(A)(Central), Gurgaon. The Ld. Cit(A) Vide Order, Dated 26.04.2019 Sustained The Penalty Of Rs. 1,58,68,413/-, Against That Order, The Assessee Has Filed This Appeal Before The 2

For Appellant: Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

Section 154Section 271Section 271ASection 274

Constructions Pvt.Ltd. Vs DCIT, as reported in 48 CCGH 0178, wherein the decision of Hon'ble Apex Court have been followed for deletion of penalty u/s 271 AAA. 9 iii). Chandigarh Bench of ITAT in the case of Sh. Satish Goyal in ITYA No.636/Chd/2016, wherein the decision ... Apex Court have been followed for deletion of penalty u/s 271AAA. iv). The judgment of Apex Court in the case of ACIT Vs Gebital Kanhaialal HUF, as reported in 348 ITR 561. 10. The Ld. Counsel also referred to the statement of Sh. Jarnail Singh Bajwa, as recorded during search

M/S Bajwa Developers Ltd., Kharar vs. DCIT, CC-II, Chandigarh

ITA 1529/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh22 Apr 2025AY 2012-13

Bench: The Cit(A)(Central), Gurgaon. The Ld. Cit(A) Vide Order, Dated 26.04.2019 Sustained The Penalty Of Rs. 1,58,68,413/-, Against That Order, The Assessee Has Filed This Appeal Before The 2

For Appellant: Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR

Section 154Section 271Section 271ASection 274

Constructions Pvt.Ltd. Vs DCIT, as reported in 48 CCGH 0178, wherein the decision of Hon'ble Apex Court have been followed for deletion of penalty u/s 271 AAA. 9 iii). Chandigarh Bench of ITAT in the case of Sh. Satish Goyal in ITYA No.636/Chd/2016, wherein the decision ... Apex Court have been followed for deletion of penalty u/s 271AAA. iv). The judgment of Apex Court in the case of ACIT Vs Gebital Kanhaialal HUF, as reported in 348 ITR 561. 10. The Ld. Counsel also referred to the statement of Sh. Jarnail Singh Bajwa, as recorded during search

Vinod Ramchandra Jadhav, Pune vs. DCIT, CC-2(1), Pune

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 2144/PUN/2024[AY 2010-11]Status: DisposedITAT Pune21 Apr 2025

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR

Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

Assessing Officer. 14. Based on the arguments advanced by the assessee, the Ld. CIT(A) deleted the penalty levied by the Assessing Officer u/s 271(1)(c) of the Act being barred by limitation by observing as under: “Finding: 5.2 I have considered the facts of the case ... Tribunal by raising the following grounds: 01. On the facts and the circumstances and in law, the Ld. CIT(A) has erred in deleting the penalty u/s 271(1)(c) of the Income-tax Act, 1961 only on technical grounds and not on the merits of the case, without appreciating

DCIT, CC-2(1), Pune vs. Vinod Ramchandra Jadhav, Pune

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 1307/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2025AY 2010-11

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR

Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

Assessing Officer. 14. Based on the arguments advanced by the assessee, the Ld. CIT(A) deleted the penalty levied by the Assessing Officer u/s 271(1)(c) of the Act being barred by limitation by observing as under: “Finding: 5.2 I have considered the facts of the case ... Tribunal by raising the following grounds: 01. On the facts and the circumstances and in law, the Ld. CIT(A) has erred in deleting the penalty u/s 271(1)(c) of the Income-tax Act, 1961 only on technical grounds and not on the merits of the case, without appreciating

Deputy Commissioner of Income Tax, (It)-4(2)(1), Mumbai vs. M/S. Siemens, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3109/MUM/2016[2008-09]Status: DisposedITAT Mumbai05 Mar 2025AY 2008-09

Bench: Shri Amarjit Singhshri Sandeep Singh Karhaildeputy Commissioner Of Income Tax, (It)-4(2)(1), Scindia House, Balard Pier, N.M. Road, Mumbai – 400038 ……………. Appellant Maharashtra V/S M/S. Siemens Aktiengensellschaft, C/O, Bsr & Co. Lodha Excelus, 1St Floor, Apollo Mills Compound, M.N. Joshi Marg, Mahalaxmi, ……………. Respondent Mumbai - 400038, Maharashtra Pan – Aabcs8516K

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Ajay Chandra, CIT-DR

Section 142(1)Section 143(2)Section 250Section 271GSection 92CSection 92D

raised the following grounds: – “1) "Whether on the facts and circumstances of the case and in law, the CIT(A) was justified in deleting the penalty of Rs. 37,52,08,140/- levied u/s. 271G of the Act, which had been initiated for failure to furnish information or documents under ... aside on the above grounds) and the order of the Assessing Officer restored.” 3. The solitary grievance of the Revenue is against the deletion of penalty under section 271G of the Act. 4. The brief facts of the case pertaining to this issue as emanating from the record

Deejay Stocks Private Limited, Mumbai vs. DCIT4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4692/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Feb 2025AY 2015-16

Bench: Us It Has Been Submitted That In Assessee’S Own Case For The A.Y.2014-15 & 2016-17 Similar Penalty Levied Has Been Deleted By The Tribunal. For The Sake Of Ready Reference The Relevant Finding Reads As Under:

Section 271(1)Section 271(1)(b)Section 271(1)(c)Section 271BSection 273B

Certificate of Director's Mother would explain and substantiate the reasonableness for non appearance even before the Ld.CIT(A). He thus prayed for deletion of penalty u/s. 271(1) (b) r.w.s.273B of the act. 4.2. On the other hand, the learned Departmental representative strongly supporting the order of the Commissioner ... view of the above, we are unable to uphold the order of the authorities below. We thus direct to delete the penalty levied under section 271(1)(b) of the act in the hands of the assessee. 4. Since on similar facts penalty has been deleted for earlier and subsequent

DCIT Circle-3 Thane, Thane vs. Dayanand Damodar Patil, Thane

In the result, appeal of the Revenue is dismissed

ITA 3354/MUM/2024[2012-13]Status: DisposedITAT Mumbai28 Feb 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 139Section 139(4)Section 143(2)Section 271(1)Section 271(1)(c)

against order dated 17/04/2024 passed by NFAC, Delhi in relation to penalty proceedings u/s. 271(1)(c). 2. The Revenue is aggrieved by deletion of penalty of Rs.3,00,58,858/- which was levied by the ld. AO on the income offered by the assessee in the return of income ... been accepted by the ld. AO. Thus in such a case, no penalty can be levied. Accordingly, the ld. CIT(A) has rightly deleted the penalty. 5. In the result, appeal of the Revenue is dismissed. Order pronounced on 28th February, 2025. (GIRISH AGRAWAL) JUDICIAL MEMBER Mumbai; Dated 28/02/2025 KARUNA

DCIT-1(2)1, Mumbai vs. Bombay Rayon Holdings Limited, Mumbai

In the result, all the four appeals by the Revenue having common ground are dismissed

ITA 5606/MUM/2024[2010-11]Status: DisposedITAT Mumbai27 Feb 2025AY 2010-11

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawal

For Appellant: NoneFor Respondent: Shri Kailash C, Kanojiya, CIT DR

Section 133ASection 143(3)Section 148Section 271(1)(c)

adjudication. 3. This is a set of four appeals by the Revenue having identical set of factual matrix with common ground challenging deletion of penalty levied under section 271(1)(c). Since ground raised is common, we adjudicate all the four appeals by passing a consolidated order with facts drawn ... under section 271(1)(c) for furnishing inaccurate particulars of income. Aggrieved, assessee went in appeal before CIT(A) who deleted the penalty so levied. Against this, Revenue is in appeal before the Tribunal. Bombay Rayon Holdings Ltd., AYs 2014-15, 2013-14, 2011-12 and 2010-11 4.4. According

DCIT-1(2)1, Mumbai vs. Bombay Rayon Holdings Limited, Mumbai

In the result, all the four appeals by the Revenue having common ground are dismissed

ITA 5605/MUM/2024[2011-12]Status: DisposedITAT Mumbai27 Feb 2025AY 2011-12

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawal

For Appellant: NoneFor Respondent: Shri Kailash C, Kanojiya, CIT DR

Section 133ASection 143(3)Section 148Section 271(1)(c)

adjudication. 3. This is a set of four appeals by the Revenue having identical set of factual matrix with common ground challenging deletion of penalty levied under section 271(1)(c). Since ground raised is common, we adjudicate all the four appeals by passing a consolidated order with facts drawn ... under section 271(1)(c) for furnishing inaccurate particulars of income. Aggrieved, assessee went in appeal before CIT(A) who deleted the penalty so levied. Against this, Revenue is in appeal before the Tribunal. Bombay Rayon Holdings Ltd., AYs 2014-15, 2013-14, 2011-12 and 2010-11 4.4. According

DCIT-1(2)1, Mumbai vs. Bombay Rayon Holdings Limited, Mumbai

In the result, all the four appeals by the Revenue having common ground are dismissed

ITA 5604/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Feb 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon’Ble & Shri Girish Agrawal

For Appellant: NoneFor Respondent: Shri Kailash C, Kanojiya, CIT DR

Section 133ASection 143(3)Section 148Section 271(1)(c)

adjudication. 3. This is a set of four appeals by the Revenue having identical set of factual matrix with common ground challenging deletion of penalty levied under section 271(1)(c). Since ground raised is common, we adjudicate all the four appeals by passing a consolidated order with facts drawn ... under section 271(1)(c) for furnishing inaccurate particulars of income. Aggrieved, assessee went in appeal before CIT(A) who deleted the penalty so levied. Against this, Revenue is in appeal before the Tribunal. Bombay Rayon Holdings Ltd., AYs 2014-15, 2013-14, 2011-12 and 2010-11 4.4. According