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“Section 124(3)(c)”

Section References (mined)Section 124Section 124(3)(c)6 judgments

The decision most relied on for Section 124(3)(c) is Pr. CIT v. Golden Peace Hotels and Resorts (P) Ltd. (124 Taxmann.com 249), cited in 105 judgments on BharatTax.

Leading authorities on Section 124(3)(c)

Pr. CIT v. Golden Peace Hotels and Resorts (P) Ltd.
124 Taxmann.com 249 · 2021 · Supreme Court
105
citing judgments

A penalty levied under Section 271(1)(c) is not sustainable if the notice issued under Section 274 fails to specifically mention whether the charge relates to concealment of income or furnishing inaccurate particulars of income. The Assessing Officer must specify the exact charge for the penalty to be valid.

Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal
241 ITR 124 · 2000 · High Court
89
citing judgments

A penalty for concealment of income cannot be levied if an assessee files a revised return to buy peace and avoid litigation, and the revenue accepts this without objection.

(iv) CIT v. British India Corporation Ltd.
337 ITR 64 · 2011 · High Court
19
citing judgments

A question of an Assessing Authority's jurisdiction cannot be disputed after assessment proceedings are completed. Such disputes can only be decided by the Commissioner or the Board, not by an appellate authority under Section 246.

(P.) Ltd. v. ITO 9(1)(1), Mumbai
124 Taxmann.com 72 · 2021 · High Court
15
citing judgments

Cash credits received as share capital and share premium are considered unexplained under Section 68 if the assessee fails to prove the identity, creditworthiness, and genuineness of the transaction. The Assessing Officer can make an addition on this basis.

Judgments citing Section 124(3)(c)

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 509/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 508/JPR/2025[2020-21]Status: DisposedITAT Jaipur12 Nov 2025AY 2020-21

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 507/JPR/2025[A.Y. 2018-19]Status: DisposedITAT Jaipur12 Nov 2025

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 506/JPR/2025[2016-17]Status: DisposedITAT Jaipur12 Nov 2025AY 2016-17

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Sonu Dusad, Jaipur vs. DCIT Central Circle, 1, Jaipur

In the results, the appeal of the assessee in ITA no

ITA 505/JPR/2025[2015-16]Status: DisposedITAT Jaipur12 Nov 2025AY 2015-16

Bench: This Tribunal Are As Under :

For Appellant: Sh. Mukesh Soni, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 144CSection 153CSection 153DSection 250

complete absence of jurisdiction in violation of CBDT guidelines or direction as issued u/s 120 of the Act. 23. Further, according to Section 124(3)(c) of the Act, the Assessee has the right to object to the jurisdiction at any time within one month from the date the notice

Addl CIT R G 7(1), Mumbai vs. Novartis India Ltd ( Formerly Known As Hindustan Ciba Giegy Ltd. ), Mumbai

ITA 6772/MUM/2010[2002-03]Status: DisposedITAT Mumbai20 Mar 2024AY 2002-03

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 2

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B”, MUMBAI BEFORE SHRI AMIT SHUKLA, HON'BLE JUDICIAL MEMBER AND SHRI