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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)

Dy Commissioner of Income Tax -5(2)(1), Mumbai vs. Imi Alloys Private Limited, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 4366/MUM/2023[2010-11]Status: DisposedITAT Mumbai09 May 2024AY 2010-11

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(c)

estimations. There is no definite finding on the quantum of concealment of income. It is an accepted legal position that penalty under section 271(1)(c) of the Act levied on additions made merely on estimations is unsustainable 4.2. The Hon'ble Rajasthan High Court in the case

Dy. Commissioner of Income Tax -5(2)(1), Mumbai vs. Imi Alloys Private Limited, Mumbai

In the result, appeals of the Revenue are dismissed

ITA 4365/MUM/2023[2011-12]Status: DisposedITAT Mumbai09 May 2024AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(c)

estimations. There is no definite finding on the quantum of concealment of income. It is an accepted legal position that penalty under section 271(1)(c) of the Act levied on additions made merely on estimations is unsustainable 4.2. The Hon'ble Rajasthan High Court in the case

The DCIT, Central Circle-2, Vadodara vs. M/S. Neotech Education Foundation, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 47/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting the penalty levied under Section 271(1)(c) of the I.T. Act to Rs.3,05,953/- as against penalty of Rs.1,31,79,630/- levied by the Assessing Officer ... determining the total income of the assessee company at Rs.16,25,46,276/-. While finalising the assessment, the penalty proceedings under Section 271(1)(c) of the Act were initiated for concealment of income on the issues appearing at Sl. Nos.1 to 7 and 10 as well as initiated penalty

The DCIT, Central Circle-2, Vadodara vs. M/S. Neotech Education Foundation, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 192/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting the penalty levied under Section 271(1)(c) of the I.T. Act to Rs.3,05,953/- as against penalty of Rs.1,31,79,630/- levied by the Assessing Officer ... determining the total income of the assessee company at Rs.16,25,46,276/-. While finalising the assessment, the penalty proceedings under Section 271(1)(c) of the Act were initiated for concealment of income on the issues appearing at Sl. Nos.1 to 7 and 10 as well as initiated penalty

M/S. Neotech Education Foundation, Vadodara vs. The Jt.CIT, Central Range, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 109/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting the penalty levied under Section 271(1)(c) of the I.T. Act to Rs.3,05,953/- as against penalty of Rs.1,31,79,630/- levied by the Assessing Officer ... determining the total income of the assessee company at Rs.16,25,46,276/-. While finalising the assessment, the penalty proceedings under Section 271(1)(c) of the Act were initiated for concealment of income on the issues appearing at Sl. Nos.1 to 7 and 10 as well as initiated penalty

M/S. Neotech Education Foundation, Vadodara vs. The Jt.CIT, Central Range, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 108/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting the penalty levied under Section 271(1)(c) of the I.T. Act to Rs.3,05,953/- as against penalty of Rs.1,31,79,630/- levied by the Assessing Officer ... determining the total income of the assessee company at Rs.16,25,46,276/-. While finalising the assessment, the penalty proceedings under Section 271(1)(c) of the Act were initiated for concealment of income on the issues appearing at Sl. Nos.1 to 7 and 10 as well as initiated penalty

Image Finvest & Leasing Pvt. Ltd., Kolkata vs. ITO, Ward-11(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 88/KOL/2024[2015-16]Status: DisposedITAT Kolkata08 May 2024AY 2015-16

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Bleassessment Year: 2015-16 Image Finvest & Leasing Pvt. Ltd. Ito, Ward-11(4), Kolkata 200, Block-A, Bangur Avenue, Vs Kolkata-700055 Pan: Aaaci 5378 J (Appellant) (Respondent) Present For: Appellant By : Shri Anil Kochar, Ar Respondent By : Shri P.P. Barman, Addl. Cit, Sr. Dr Date Of Hearing : 27.03.2024 Date Of Pronouncement : 08.05.2024 O R D E R Per Sonjoy Sarma, Jm: This Appeal Of The Assessee For The Assessment Year 2015-16 Is Directed Against The Order Dated 09.01.2024 Passed By The Ld. Commissioner Of Income-Tax (Appeals), Nfac, Delhi [Hereinafter Referred To As ‘The Ld. Cit(A)’].

For Appellant: Shri Anil Kochar, ARFor Respondent: Shri P.P. Barman, Addl. CIT, Sr. DR
Section 143(3)Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH ‘B’, KOLKATA BEFORE SHRI RAJESH KUMAR, HON’BLE ACCOUNTANT MEMBER AND SHRI

Pijush Kanti Bhunia, Kolkata vs. ITO, Ward-39(1), Midnapore

The appeals of the assessee stand allowed

ITA 328/KOL/2024[2016-17]Status: DisposedITAT Kolkata08 May 2024AY 2016-17

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.327&328/Kol/2024 Assessment Years: 2016-17 Pijush Kanti Bhunia….……..…..…......................…...……………....Appellant C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Agrpb9773C] Vs. Ito, Ward-39(1), Midnapore……………............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 02, 2024 Date Of Pronouncing The Order : May 08, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are The Two Appeals Preferred By The Assessee, One Is Pertaining To The Quantum Addition & The Other Is Deleting To The Levying Of Penalty U/S 271(1)(C) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). First, We Take Assessee’S Appeal Relating To Quantum Addition & Second Is Penalty Addition. 2. Ita No.327/Kol/2024 - The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. For That The Ld. Cit(A) Ought To Have Considered That The Recorded Reasons To Believe Are Invalid & Improper & As Such, The Reassessment Framed Vide Order Dated19.12.2019 Is Bad In Law & Is Liable To Be Quashed.

Section 271(1)(c)

आयकर अपील"य अ"धकरण, कोलकाता पीठ ‘बी’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA Before Shri

Pijush Kanti Bhunia, Midnapur vs. ITO, Ward-39(1), Midnapore

The appeals of the assessee stand allowed

ITA 327/KOL/2024[2016-17]Status: DisposedITAT Kolkata08 May 2024AY 2016-17

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.327&328/Kol/2024 Assessment Years: 2016-17 Pijush Kanti Bhunia….……..…..…......................…...……………....Appellant C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Agrpb9773C] Vs. Ito, Ward-39(1), Midnapore……………............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 02, 2024 Date Of Pronouncing The Order : May 08, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Are The Two Appeals Preferred By The Assessee, One Is Pertaining To The Quantum Addition & The Other Is Deleting To The Levying Of Penalty U/S 271(1)(C) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). First, We Take Assessee’S Appeal Relating To Quantum Addition & Second Is Penalty Addition. 2. Ita No.327/Kol/2024 - The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. For That The Ld. Cit(A) Ought To Have Considered That The Recorded Reasons To Believe Are Invalid & Improper & As Such, The Reassessment Framed Vide Order Dated19.12.2019 Is Bad In Law & Is Liable To Be Quashed.

Section 271(1)(c)

आयकर अपील"य अ"धकरण, कोलकाता पीठ ‘बी’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA Before Shri

Mithalal Ratanchand Jain, Mumbai vs. Commissioner of Income (A)-11, Pune

In the result, appeal of the assessee is allowed

ITA 4316/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 May 2024AY 2012-13

Bench: Shri Girish Agrawal & Shri Sunil Kumar Singhassessment Year: 2012-13 Mithalalratanchand Jain Commissioner Of Income Tax 2Nd Floor, Shanti Niwas, (A)-11, Pune New Golden Nest Phase-Xiii, Vs. 100 Ft. Road, Bhayander(East), Mumbai – 401105 (Pan : Aappj1942F) (Appellant) (Respondent)

For Appellant: Shri Vimal Punmiya, CAFor Respondent: Smt. Mahita Nair,Sr.DR
Section 132Section 153ASection 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH MUMBAI BEFORE SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR SINGH

Anil Tarachand Kadu, Ahmednagar vs. Deputy Commissioner of Income Tax, Central Circle -1(1), Pune

ITA 1058/PUN/2023[2013-14]Status: DisposedITAT Pune07 May 2024AY 2013-14

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1058/Pun/2023 िनधा"रण वष" / Assessment Year: 2013-14 Anil Tarachand Kadu, The Deputy Gut No.115, Ranjankhol, V Commissioner Of Income Tilaknagar, Ahmednagar, S Tax, Central Cirlce-1(1), Ahmednagar – 413720. Pune. Pan: Aplpk9182P Appellant/ Revenue Respondent /Assessee Assessee By Shri Vinita Shah – Ar Revenue By Shri Keyur Patel – Cit-Dr Date Of Hearing 02/05/2024 Date Of Pronouncement 07/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2013-14 Dated 07.08.2023 Emanating From The Penalty Order U/S.271(1)(C) Of The Act, 1961 Dated 20.06.2018. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & Circumstances Of The Case As Well As In Law, The Learned Cit(A) Has Erred In Passing The Ex-Parte Order, Without Anil Tarachand Kadu [A]

Section 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 271(1)(c)

आयकर अपीलीय अिधकरण ”ए” "ायपीठ पुणेम"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE SHRI S.S.GODARA, JUDICIAL

Abdul Nayab Shaikh, Mumbai vs. ITO Ward 23(1)(1), Maturmandir, Mumbai

The appeal is dismissed

ITA 4012/MUM/2023[2011-12]Status: DisposedITAT Mumbai07 May 2024AY 2011-12

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal

Section 139(1)Section 143(3)Section 147Section 148Section 250Section 4Section 54Section 54F

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI GAGAN GOYAL

Arvind Kumar Taneja (HUF), New Delhi vs. ITO, Ward-52(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 842/DEL/2023[2011-12]Status: DisposedITAT Delhi07 May 2024AY 2011-12

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Shreyansh Kushwaha, AdvFor Respondent: Sh. Kanv Bali, Sr. DR
Section 133(6)Section 139Section 139(1)Section 142Section 148Section 153Section 271Section 271(1)(c)

Delhi-18/10119/2019-20 confirming the penalty of Rs.27,300/- imposed by the Income-tax Officer, Ward-52(4), Delhi [AO'] under section 271(1)(c) of the Income-tax Act, 1961 [the 'Act']. 2. That on the facts and circumstances of the case, the learned CIT(A) erred on facts ... Income Tax Act, 1961. Accordingly, I find it is a fit case for imposing penalty in view of Explanation-III to Section 271(1)(c) of the Income Tax Act, 1961.” 3 Arvind Kumar Taneja (HUF) 6. Explanation 3 of Section 271 reads as under: “Explanation 3.—Where any person

Sri Sanat Kumar Das, Kolkata vs. DCIT, (I.T.), Cir. 2(1), Kolkata

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

ITA 202/KOL/2024[2014-15]Status: DisposedITAT Kolkata06 May 2024AY 2014-15

Bench: Sri Rajpal Yadav, Vice- & Sri Sanjay Awasthi

Section 143(3)Section 154Section 250Section 27(1)(c)Section 271Section 271(1)(c)Section 274Section 90Section 90(2)

already suffered taxation in the UK. 4.1. Ld. A/R also argued that the notice issued by the AO u/s 274 read with Section 271(1)(c) of the Act was not maintainable because ld. AO had not specified whether he intended to levy penalty for concealment of income ... favour of the assessee, there appears to be no need to express any opinion regarding the maintainability of notice u/s 274 read with Section 271(1)(c) of the Act, which led to the levy of penalty in the impugned order. 8. In the result, the appeal filed

Vijay Pai Natasha, Chennai vs. ITO, Ncw1(4), Chennai

The appeal stand allowed for statistical purposes

ITA 473/CHNY/2024[2011-12]Status: DisposedITAT Chennai06 May 2024AY 2011-12

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.473/Chny/2024 (िनधा(रण वष( / Assessment Year: 2011-12) Shri Vijay Pai Natasha Ito बनाम 16, Vellaiyan Road, Kotturpuram, Non-Corporate Ward-1(4) / Vs. Chennai-600 085. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Afepn-0433-P (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : None " थ"कीओरसे/Respondent By : Shri Ar V Sreenivasan (Addl. Cit) - Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 30-04-2024 घोषणाकीतारीख /Date Of Pronouncement : 06-05-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: NoneFor Respondent: Shri AR V Sreenivasan (Addl. CIT) - Ld. Sr. DR
Section 271(1)(c)

आयकर अपीलीय अिधकरण “ए” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHENNAI माननीय "ी मनोज कुमार

Bbr (India) Pvt Ltd., Bangalore vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Bangalore

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

ITA 468/BANG/2024[2009-10]Status: DisposedITAT Bangalore06 May 2024AY 2009-10

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessmentyear:2009-10

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Sri Subramanian S., D.R
Section 143(3)Section 250Section 271(1)(c)

ITA No.468/Bang/2024 BBR (India) Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’BENCH: BANGALORE BEFORE SHRI LAXMI PRASAD

Unicorn Infoservices Private Limited, Mumbai vs. National Faceless Appeals Centre, New Delhi

In the result, the regular ground raised by the

ITA 4190/MUM/2023[2011-12]Status: DisposedITAT Mumbai06 May 2024AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2011-12

For Appellant: Mr. Vickey Chedda/Mr. Jainam GalaFor Respondent: 02/05/2024
Section 148Section 271(1)(c)Section 274

Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2010-11 in relation to penalty under section 271(1)(c) of the Income-tax Act 1961 ( in short the ‘Act’). The relevant grounds raised by the assessee are reproduced as under: Unicorn Infoservices ... u/s.274 r.w.s.271(1)(c) dated 29/11/2018 notice u/s.274 r.w.s.271(1)(c) dated 29/11/2018, refers to both the , refers to both the limbs of section 271(1)(c) of the Income Tax Act, 1961. limbs of section 271(1)(c) of the Income Tax Act, 1961. 3. The Learned Commissioner

Rajinder Sharma, Gurgaon vs. ACIT, Gurgaon

In the result appeal is allowed

ITA 5176/DEL/2014[2007-08]Status: DisposedITAT Delhi06 May 2024AY 2007-08

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2007-08 Rajinder Sharma, Vs. Acit, 1205B, Beverly Park-Ii, Gurgaon Dlf City Phase Ii, Gurgaon – 122009. Pan Aibps7516G (Appellant) (Respondent)

For Appellant: Shri Rajinder Sharma in personFor Respondent: Ms. Mayuri, Sr. DR
Section 142(1)Section 143(2)Section 17(3)Section 17(3)(i)Section 17(3)(iii)Section 234Section 271(1)(c)Section 28

dated 31.12.2009 and enhanced income of assessee by Rs. 45,00,000/- charge interest under section 234 ‘A’, ‘B’ ‘C’ and penalty under section 271(1)(c) of the Income Tax Act, 1961. 3. Assessee preferred appeal before Learned Commissioner of Income Tax which was dismissed vide order dated

Smt. Renu Gupta, Ambala City vs. ITO, Ward 3, Ambala

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

ITA 12/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh03 May 2024AY 2011-12

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Varun Gupta, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 142(1)Section 147Section 148

considered but not found acceptable to the AO. Thereafter AO assessed the income at Rs. 20,78,730/- and issued penalty notice under section 271(1)(c) of the Act. 4. Against the order of the AO, the assessee went in appeal before

Shrenik Hiralal Shah, Vadodara vs. Income Tax Officer, Ward 1(1)(3), Vadodara

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

ITA 263/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad03 May 2024AY 2010-11

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinha

For Respondent: Shri C S Sharma, Sr. DR
Section 143(3)Section 147Section 271(1)(c)Section 275Section 50C

Officer, Ward 1(1)(3), Vadodara ('the Assessing Officer' or 'the AO') in levying a penalty of Rs. 8,00,000/- under section 271(1)(c) of the Act. 4) The learned CIT(A) erred in fact and in law in confirming the action of the learned AO in levying ... fact and in law in confirming the action of the learned AO in levying a penalty of Rs. 8,00,000 under section 271(1)(c) of the Act even when the appeal against assessment order under section 147 of the Act was pending before CIT(A). 7) The learned