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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)

Bank of India, Mumbai vs. The National Faceless Assessment Centre, Mumbai

ITA 1452/MUM/2023[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

Bank of India, Mumbai vs. ACIT-2(1)(2), Mumbai

In the result, the appeal by the Revenue for the assessment year 2018-

ITA 1451/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-17

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

ACIT, Central Circle-19, Delhi vs. Yasmin Kapoor, Delhi

ITA 3379/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jan 2026AY 2016-17

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

case of Gayathri Textiles vs. CIT (2000) 111 taxman 123 (Kar) wherein the Id. CIT(A) had cancelled the penalty levied under section 271(1)(c), holding that the Id. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal ... Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from the IAC for imposing penalty under section 271(1)(c) was only a procedural error and it was not fatal to the order of penalty under section 271(1)(c

ACIT, Central Circle-19, Delhi vs. Yasmin Kapoor, Delhi

Appeals of the assessee are allowed

ITA 2221/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

case of Gayathri Textiles vs. CIT (2000) 111 taxman 123 (Kar) wherein the ld. CIT(A) had cancelled the penalty levied under section 271(1)(c), holding that the ld. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal ... Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from the IAC for imposing penalty under section 271(1)(c) was only a procedural error and it was not fatal to the order of penalty under section 271(1)(c

ACIT, Central Circle-19, Delhi vs. Deepa Talwar, Delhi

Appeals of the assessee are allowed

ITA 2203/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

case of Gayathri Textiles vs. CIT (2000) 111 taxman 123 (Kar) wherein the ld. CIT(A) had cancelled the penalty levied under section 271(1)(c), holding that the ld. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal ... Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from the IAC for imposing penalty under section 271(1)(c) was only a procedural error and it was not fatal to the order of penalty under section 271(1)(c

Yasmin Kapoor, Delhi vs. DCIT, Central Circle - 19, Delhi

ITA 1542/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Jan 2026AY 2016-17

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

case of Gayathri Textiles vs. CIT (2000) 111 taxman 123 (Kar) wherein the Id. CIT(A) had cancelled the penalty levied under section 271(1)(c), holding that the Id. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal ... Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from the IAC for imposing penalty under section 271(1)(c) was only a procedural error and it was not fatal to the order of penalty under section 271(1)(c

Ravindrabhai Shankarbhai Patel, Vadodara vs. The ITO, Ward-1(2)(5) Now ITO, Ward-1(2)(2), Vadodara

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

ITA 1061/AHD/2025[2015-16]Status: PendingITAT Ahmedabad29 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Ito Ravindrabhai Shankarbhai Vs. Ward-1(2)(5). Patel Now Ito, Ward-1(2)(2) 86,Kanha Residency Vadodara – 390 007 Kalali Road, Kalali Ahmedabad – 390 012 [Pan : Aigpp 8415 M] (Appellant) (Respondent) .. Assessee Represented By : Ms. Urvashi Shodhan, Ar Revenue Represented By : Shri Abhijit, Sr.Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 29/01/2026

Section 139(1)Section 139(4)Section 143(3)Section 144ASection 54BSection 54F

against Nil returned by the assessee and completed the assessment at a total income of Rs.1,75,34,640/-. Penalty proceedings under section 271(1)(c) of the Act were also initiated. Ravindrabhai Shankarbhai Patel vs. ITO A.Y: 2015-16 5. Aggrieved by the assessment order, the assessee carried

Bindu Dharmesh Bhatt, Vadodara vs. Asstt.CIT., Circle-1(3), Vadodara

The appeal of the assessee is allowed

ITA 618/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2011-12

For Appellant: Shri Tushar Hemani, Sr. A.RFor Respondent: Shri Rameshwar P. Meena, Sr. D.R
Section 131Section 143(1)Section 147Section 148Section 234ASection 274

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before Ms. Suchitra Kamble, Judicial Member And Shri Narendra Prasad Sinha, Accountant

Janakee Petrolium, Satara vs. ITO WD-4, Satara

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

ITA 2327/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jan 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

Section 144Section 147Section 148Section 148ASection 151ASection 250Section 271(1)(c)Section 69A

both dated 20.08.2025 emanating from the Assessment Order passed under section 147 r.w.s 144 of the Act, dated 22.02.2023 and penalty order under section 271(1)(c) of the Act, 10.08.2023 ITA Nos.2322 & 2327/PUN/2025 [A] respectively. For the sake of convenience, these two appeals were heard together and are being

Janakee Petrolium, Satara vs. ITO WD-4, Satara

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

ITA 2322/PUN/2025[2015-16]Status: DisposedITAT Pune29 Jan 2026AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2322 & 2327/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Janakee Petrolium, V Income Tax Officer, Gat No.1041/B, Wai Surru S Ward-4, Satara. Roadk Kavathe Wai, Satara – 415516 Pan: Aajfj9486C Appellant/ Assessee Respondent /Revenue Assessee By Shri Tanzil Padvekar Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 29/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Both Dated 20.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 22.02.2023 & Penalty Order Under Section 271(1)(C) Of The Act, 10.08.2023

Section 144Section 147Section 148Section 148ASection 151ASection 250Section 271(1)(c)Section 69A

both dated 20.08.2025 emanating from the Assessment Order passed under section 147 r.w.s 144 of the Act, dated 22.02.2023 and penalty order under section 271(1)(c) of the Act, 10.08.2023 ITA Nos.2322 & 2327/PUN/2025 [A] respectively. For the sake of convenience, these two appeals were heard together and are being

Rita Das, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 1389/KOL/2024[2011-2012]Status: DisposedITAT Kolkata29 Jan 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1388 & 1389/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2011-2012) Rita Das, Vs Acit, Cc-23 (1), Hooghly C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata,Wb-700001 Pan No. :Arhpd 6149 D

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Altaf Hussain, Sr. DR

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RAJESH KUMAR, ACCOUNTANT

Rita Das, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

In the result, both the appeals of the assessee are allowed

ITA 1388/KOL/2024[2011-2012]Status: DisposedITAT Kolkata29 Jan 2026AY 2011-2012

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1388 & 1389/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2011-2012) Rita Das, Vs Acit, Cc-23 (1), Hooghly C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata,Wb-700001 Pan No. :Arhpd 6149 D

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Altaf Hussain, Sr. DR

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RAJESH KUMAR, ACCOUNTANT

Mercy Education Trust, Chennai vs. ITO, Ncw-19(6), Chennai

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

ITA 2231/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Jan 2026AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2231/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mercy Education Trust, The Income Tax Officer, No.66, Sree Gokulam Towers, Vs. Non-Corporate Ward 19(6), Arcot Road, Chennai. Kodambakkam, Chennai – 600 024. Pan: Aactm 6190M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 29.01.2026

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri N. Rajakumar, Addl.CIT
Section 10Section 139Section 147Section 148Section 250Section 272A(2)(e)Section 273B

hold that the assessee can challenge the jurisdiction of Assessing Officer in passing the assessment order while challenging levy of penalty under section 271(1)(c) of the Act. In case the reassessment proceedings have been completed without proper jurisdiction entrusted upon the Assessing Officer, then the consequent penalty proceedings

Jagruti Bharat Shah, Mumbai vs. Income Tax Officer-19(3)(1), Mumbai

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

ITA 8226/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Jan 2026AY 2011-12

Bench: Shri Sandeep Singh Karhail & Shri Girish Agrawalassessment Year: 2011-12 Jagruti Bharat Shah Income Tax Officer-19(3)(1), 83 30 Rekha Bldg, Mumbai Vs. Rak Road, Wadala, Mumbai - 400031 [Pan: Aaqps1580D] (Appellant) (Respondent) Present For: Assessee : Mr. Dhaval Shah & Ms. Tisha Bagh, Advocates Revenue : Shri Pravin Salunkhe, Sr. Dr. Date Of Hearing : 28.01.2026 Date Of Pronouncement : 29.01.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Addl/Jcit (A)-2, Lucknow, Vide Order No. Itba/Apl/S/250/2025- 26/1081211974(1), Dated 26.09.2025, Passed Against The Assessment Order By Income Tax Officer, Ward-19(2)(1), Mumbai, U/S. 147 R.W.S 143(3) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 26.12.2018 For Assessment Year 2011-12. 2. Grounds Taken By Assessee Are Reproduced As Under: “1. The Ld. Cit(A) Has Erred In Law & In Facts In Passing The Order U/S. 250 Of The Act Dated 26.09.2025 Dismissing The Appeal Filed By The Appellant & Confirming The Order Passed By The Ld. Ao U/S 143(3) R.W.S 147 Of The Act Which Is Bad & Invalid In The Eyes Of Law. 2. The Ld. Cit(A) Has Erred In Law & In Facts In Not Appreciating That The Assessment Order Passed Is In Violation Of Principles Of Natural Justice.

For Appellant: Mr. Dhaval Shah and Ms. Tisha Bagh, AdvocatesFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 143(3)Section 147Section 234ASection 250Section 271(1)(c)Section 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “H (SMC)” BENCH MUMBAI BEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER AND SHRI GIRISH

Vishan Satramdas Lakhani, Mumbai vs. Pr. CIT Rang 27, Mumbai

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

ITA 7748/MUM/2025[2016-17]Status: DisposedITAT Mumbai29 Jan 2026AY 2016-17

Bench: The Cit(A). There Was Delay Of 128 Days In Filing The Appeal Before The Cit(A). The Appellant Had Submitted That He Did Not Receive Any Email Or Intimation For Passing The Assessment Order. Only After Receiving The Notice U/S 271(1)(C) On 21.08.2023, The Appellant Could Find The Impugned Assessment Order & Thereafter, He Filed The Appeal Before The Cit(A) Which Was Late By 95 Days. The Appellant Had Relied On The Decision Of Hon’Ble Supreme Court In Case Of Collector, Land Acquisition Vs. Mst. Katiji & Ors. 167 Itr 471 (Sc) & Other

Section 147Section 148Section 271(1)(c)Section 68

ITA No.7748/MUM/2025/AY 2016-17 Vishan Satramdas Lakhani accounts and mentioning any alternate application of cash by the Appellant.” 3. Facts

Income Tax Officer, Mumbai vs. M/S. Amaya Infrastructure Pvt Ltd, Palghar

In the result, the appeal of the Revenue is dismissed

ITA 5776/MUM/2025[2008-09]Status: DisposedITAT Mumbai29 Jan 2026AY 2008-09

Bench: The Hon’Ble Bombay High Court (Itxal/27362/2024) Against Quantum & The Same Is Pending?”

Section 271(1)(c)

passed by the National Faceless Appeal Centre, Delhi, whereby the learned Commissioner of Income Tax (Appeals) has deleted the penalty levied under section 271(1)(c) of the Income-tax Act, 1961, for the Assessment Year 2008-09. 2 Amaya Infrastructure Pvt. Ltd. 2. The solitary ground raised ... impugned penalty stood deleted by this Tribunal vide its order dated 10.11.2023. It is equally not in dispute that the penalty under section 271(1)(c) had been levied entirely with reference to the said addition and had no independent or separable basis dehors the quantum proceedings. 4. Once

Amit Kumar Bajaj, Mumbai vs. DCIT-24(1), Mumbai

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

ITA 1309/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Jan 2026AY 2011-12

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramit Kumar Bajaj Dcit-24(1), A-3001, Omkar, Off Dr. Piramal Chambers, Annie Besant Road, Near Vs. Lalbaug, Mumbai- Neelam Centre, Hanuman 400 012 Nagar, Worli, Maharashtra – 400 030 Pan/Gir No. Afrpb3442B (Applicant) (Respondent) Assessee By Shri Ravi Ganatra, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 29.01.2026

Section 10(38)Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250

percent for obtaining the accommodation entry. The reassessment was completed determining total income at Rs. 1,12,80,460/-. Penalty proceedings under section 271(1)(c) were also initiated. 12. Aggrieved by the reassessment order, the assessee preferred an appeal before the CIT(A). The CIT(A) issued several notices

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 1942/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Jan 2026AY 2013-14

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Assessee by
Section 143(1)Section 271Section 271(1)(c)

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed

Rajesh B. Jain As Legal Heir of Bhanwarlal M. Jain, Mumbai vs. Ward 19(1)(1), Mumbai

ITA 1941/MUM/2024[2012-13]Status: DisposedITAT Mumbai29 Jan 2026AY 2012-13

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Shri Ganesh Sudhakar Bare, CIT-
Section 271Section 271(1)(c)

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the ITA Nos. 1936 to 1942/Mum/2024 Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except

Rajesh B. Jain As Legal Heir of Bhanwarlal M Jain, Mumbai vs. Income Tax Officer, Ward-19(1)(1), Mumbai

ITA 1940/MUM/2024[2010-11]Status: DisposedITAT Mumbai29 Jan 2026AY 2010-11

Bench: Justice (Retd.) C V Bhadang & Shri Arun Khodpia, Am

For Appellant: Shri Madhur Agarwal, AdvFor Respondent: Assessee by
Section 143(1)Section 271Section 271(1)(c)

representing the assessee (appellant) that all the aforesaid appeals arise against the penalty proceedings initiated and completed against the assessee under section 271(1)(c) r.w.s. 274 of the Act. It is further clarified that these appeals are assailed with the identical grounds of appeal, challenging the legality of notices ... issued under section 271(1)(c) of the Act, as well as on merits for imposing of such penalties. Since, all the aforesaid appeals are of the Rajesh B. Jain as Legal Heir of Bhanwarlal Jain same assessee, having identical / interconnected facts and circumstances, except the quantum of penalty imposed