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“Section 271(1)(c)”

Section References (mined)Section 271Section 271(1)(c)8,984 judgments

The decision most relied on for Section 271(1)(c) is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on Section 271(1)(c)

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.

Godrej & Boyce Mfg. Co. Ltd. v. DCIT
328 ITR 81 · 2010 · High Court
1,183
citing judgments

Rule 8D, for computing disallowance under Section 14A for expenses related to exempt income, applies from Assessment Year 2008-09 onwards; for prior years, a reasonable disallowance must be made. The disallowance under Section 14A cannot exceed the actual exempt income earned.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

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.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

CIT v. Jet Airways (I) Ltd.
331 ITR 236 · 2011 · High Court
694
citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Judgments citing Section 271(1)(c)

Motorol Lubricants Limited, Vadodara vs. Assisstant Commissioner of Income Tax, Circle 4, Vadodara

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

ITA 1203/AHD/2024[2006-07]Status: DisposedITAT Ahmedabad20 Mar 2025AY 2006-07

Bench: Shri Sanjay Garg (Judicial Member)

For Appellant: NoneFor Respondent: Adjournment Application
Section 271(1)(c)Section 40A(2)

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before: Shri Sanjay Garg, Judicial Member ITA No. 1203 /Ahd/2024 Assessment Year

Shivratan Motilalji Rathi HUF, India vs. Income Tax Officer, Ward-1, Jalna, India

In the result, all the three appeals of the assessee are allowed

ITA 2599/PUN/2024[2007-08]Status: DisposedITAT Pune20 Mar 2025AY 2007-08

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.2599, 1704 & 2256/Pun/2024 Assessment Years : 2007-08, 2009-10 & 2010-11

For Appellant: Smt. Smruti SabniaFor Respondent: Shri Arvind Desai
Section 147Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL

Shivratan Motilalji Rathi HUF, Pune vs. ITO Jalna, Jalna

In the result, all the three appeals of the assessee are allowed

ITA 2256/PUN/2024[2010-11]Status: DisposedITAT Pune20 Mar 2025AY 2010-11

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.2599, 1704 & 2256/Pun/2024 Assessment Years : 2007-08, 2009-10 & 2010-11

For Appellant: Smt. Smruti SabniaFor Respondent: Shri Arvind Desai
Section 147Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL

Shivratan Motilal Rathi, Jalna vs. Income Tax Officer, Ward-1, Jana, Jalna

In the result, all the three appeals of the assessee are allowed

ITA 1704/PUN/2024[2009-10]Status: DisposedITAT Pune20 Mar 2025AY 2009-10

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.2599, 1704 & 2256/Pun/2024 Assessment Years : 2007-08, 2009-10 & 2010-11

For Appellant: Smt. Smruti SabniaFor Respondent: Shri Arvind Desai
Section 147Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND MS. ASTHA CHANDRA, JUDICIAL

Shri Abhijit Uttamrao Deshmukh, Beed vs. Assistant Commissioner of Income Tax, Circle-3, Aurangabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1666/PUN/2024[2011-12]Status: DisposedITAT Pune20 Mar 2025AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2011-12

For Appellant: Shri Prateek JhaFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 144Section 147Section 148Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

ACIT, Central Circle-2(3), Pune vs. Praphull Kaluram Shivale, Pune

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

ITA 1317/PUN/2024[2016-17]Status: DisposedITAT Pune20 Mar 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17

For Appellant: S/Shri B.C. Malakar and Yuvraj ChavanFor Respondent: Shri Arvind Desai, Addl. CIT-DR
Section 154Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA

M/S Manisha Rubber Enterprises, Mulund West vs. Income Tax Officer Ward 41(2)(3), Mumbai, Bandra East

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

ITA 454/MUM/2025[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhriआयकर अपील सं./Ita No. 454/Mum/2025 (निर्धारण वर्ा / Assessment Year :2010-11) M/S. Manisha Rubber V/S. Ito, Ward 41(2)(3), Enterprises बिधम Mumbai 50, Unique Industrial Kautilya Bhavan, C-41 To C- Estate, Dr. R. P. Road, 43, G Block, Bandra Kurla Mulund (W), Complex, Bandra (E), Mumbai-400080 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaafm6198D Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri R. R. Makwana
Section 250Section 271Section 271(1)(c)

Honourable C.I.T.(A) has erred in confirming the Penalty of Rs.1,60,638/- levied by the Assessing Officer under section 271[1][c] of Income Tax Act, 1961.” 3. Brief facts of the case are that the assessee filed a manual appeal on 28.04.2016 against the order imposing penalty

Credit Agricole Corporate and Investment Bank, Mumbai vs. The Dy-CIT (Int. Taxation)-2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 749/MUM/2022[2017-18]Status: DisposedITAT Mumbai20 Mar 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised ... marketing of derivative products (60% of INPV was attributed) Levy of interest under section 234B Ground No.26 Ground No.19 Levy of penalty under section 271(1)(c) Ground No.27 Ground No.20 Cost incurred by HO/OB towards credit risk Ground No.6 - assistance, EDP assistance HO-System Implementation Charges, on behalf

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Dy.CIT of Income Tax (Internationsl Taxation) -2(1) (1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1234/MUM/2022[2018-19]Status: DisposedITAT Mumbai20 Mar 2025AY 2018-19

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised ... marketing of derivative products (60% of INPV was attributed) Levy of interest under section 234B Ground No.26 Ground No.19 Levy of penalty under section 271(1)(c) Ground No.27 Ground No.20 Cost incurred by HO/OB towards credit risk Ground No.6 - assistance, EDP assistance HO-System Implementation Charges, on behalf

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2 & 3 Ground No.4 Ground No.6 Ground No.5 to 12 Ground

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

No.14 & 15 Ground No.17 & 18 Ground No.19 Ground No.20 Ground No.22 Ground No.23 Levy of interest under section 234B Levy of penalty under section 271(1)(c) 45. From the above table it is clear that the grounds of the assessee and the revenue raised

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 4652/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Mar 2025AY 2013-14

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent)

Section 143(3)

Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2 & 3 Ground No.4 Ground No.6 Ground No.5 to 12 Ground

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under Section 234B Ground No.19 Ground No.22 Levy of penalty under Section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised ... INPV was attributed) Ground No.10 Ground No.18 Levy of interest under Section 234B Ground No.26 Ground No.19 Levy of penalty under Section 271(1)(c) Ground No.27 Ground No.20 Cost incurred by HO/OB towards credit risk assistance, EDP assistance HO-System Implementation Charges, on behalf of Indian Branch

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

commission earned by Hong Kong Branch on ECB to Indian borrowers Levy of interest under section 234B Levy of penalty under section 271(1)(c) AY 2011-12 Ground No.1 AY 2010-11 Ground No.1 Ground No.2 & 3 Ground No.2 & 3 Ground No.4 Ground No.6 Ground No.5 to 12 Ground

ADIT (It) 1(2), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1839/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

Section 143(3)

Kong Branch on ECB to 15 & 18 Indian borrowers Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised ... marketing of derivative products (60% of INPV was attributed) Levy of interest under section 234B Ground No.26 Ground No.19 Levy of penalty under section 271(1)(c) Ground No.27 Ground No.20 Cost incurred by HO/OB towards credit risk Ground No.6 - assistance, EDP assistance HO-System Implementation Charges, on behalf

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1479/MUM/2015[2010-11]Status: DisposedITAT Mumbai20 Mar 2025AY 2010-11

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent)

Section 143(3)

Indian borrowers Ground No.14 & 15 Ground No.17 & 18 Levy of interest under section 234B Ground No.19 Ground No.22 Levy of penalty under section 271(1)(c) Ground No.20 Ground No.23 45. From the above table it is clear that the grounds of the assessee and the revenue raised

Ram Das, Delhi vs. ITO, Ward 43(1), New Delhi

ITA 2828/DEL/2023[2015-16]Status: DisposedITAT Delhi20 Mar 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 Vs. Ito, Prakash, Vill.-Daulatpur, Ward-43(3), P.O.-Khari Jatmal, New Delhi Najafgarh, New Delhi Pan: Bvppp2030L (Appellant) (Respondent) With Ita No.213/Del/2020 & 2828/Del/2023 Assessment Year: 2015-16 Sh. Ram Dass, Vs. Ito, H. No. 31, Vill.-Daulatpur, Ward-43(3), P.O.-Khari Jatmal, New Delhi Najafgarh, New Delhi Pan:Bhnpd4709L (Appellant) (Respondent) Assessee By Sh. Ankit Kumar, Adv. Sh. Sidhant Arora, Ca Department By Ms. Harpreet Karu Hansra, Sr. Dr Date Of Hearing 20.03.2025 Date Of Pronouncement 20.03.2025 Order Per Satbeer Singh Godara, Jm Instant Batch Of Three Appeals Pertain To The Twin Assesses, Herein, S/Sh. Prakash & Ram Dass. The Above Former Assessee’S

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

212/Del/2020 and 2013/Del/2020 succeed in very terms. Same order to follow in the latter assessee’s appeal ITA No.2828/Del/2023 since involving the consequential section 271(1)(c) penalty proceeding. 6. To sum up, these three assessees’ instant three appeals ITA No. 212 & 213/Del/2020 & 2828/Del/2023 are allowed in above terms

Classone Exports Pvt. Ltd., New Delhi vs. ITO Ward -6(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 5142/DEL/2019[2014-15]Status: DisposedITAT Delhi20 Mar 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalito, Ward-6(2) Class One Exports New Delhi. Pvt. Ltd. Vs. Flat No.10, C ½ Model Town, Delhi-110009 Pan: Aaacc3806H (Appellant) (Respondent) Assessee By Sh. Ajay Kumar, Employee Of Company Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 25/02/2025 Date Of Pronouncement 25/02/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Passed U/S 250 Of The Income Tax Act, 1961 (The Act, In Short) By The Ld. Commissioner Of Income Tax (Appeals)-2 In Appeal No.10647/16-17 Dated 12.03.2019 For Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is Private Limited Company & Engaged In The Business Of Trading In Shares & Securities. The Return Of Income Was Filed On 30.09.2014 Declared Nil Income Which Stood Processed. Thereafter, The Case Was Selected For Class One Exports Pvt. Ltd. Vs. Ito Scrutiny Through Cass & The Assessment Was Completed Vide Order Dated 30.12.2016 Wherein The Income Under The Head Of Business In Profession Was Estimated On The Turnover Of Rs.31,28,79,852/- By Applying Profit Rate Of 2% & Net Addition Of Rs.62,57,597/- Was Made In The Hands Of The Assessee. Against Such Order The Appeal Was Filed Before Ld. Cit(A) Who Dismissed The Appeal Of The Assessee. Thus, The Assessee Has Preferred The Appeal Before The Tribunal By Taking Following Grounds Of Appeal:- “That On The Facts & Circumstances Of The Case The Assessment Order & The Appeal Order Passed By Cit As Well As By Ito Is Bad Both On Facts & In The Eyes Of Law & Deserves To Be Quashed.

Section 133(6)Section 143(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

M/S. Uttarakhand Purv Sainik Kalyan Nigam Ltd., Dehradun vs. ITO, Dehradun

In the result, the appeal of the assessee is dismissed

ITA 725/DEL/2017[2013-14]Status: DisposedITAT Dehradun19 Mar 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Brajesh Kumar Singh[Assessment Year: 2013-14] M/S Uttrakhand Purv Ito,Ward-2(5), Sainik Kalyan Nigam Ltd. Aayakar Bhawan,13-A, Subhash (Upnl) Vs Road, Dehradun Uttrakhand- Station Sub Area, Garhi 248003 Cantt, Dehradun-248003 Pan-Aaacu7129D Assessee Revenue Assessee By Shri Tarandeep Singh, Adv. Revenue By Shri Amar Pal Singh, Sr. Dr Date Of Hearing 31.01.2025 Date Of Pronouncement 19.03.2025

Section 10Section 142(1)Section 143(3)Section 148Section 234A

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘DB’: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI BRAJESH