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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)

M D Diesel Spares, Howrah vs. ITO, Ward-47, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 1430/KOL/2023[2012-2013]Status: DisposedITAT Kolkata03 May 2024AY 2012-2013

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.1430/Kol/2023 Assessment Year: 2012-13 M D Diesel Spares………..………………………… ........................……Appellant 7/12, Kings Road, Howrah-711101. [Pan: Aakfm7649F] Vs. Ito, Ward-47(2), Kolkata..................…................…........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal & Saurabh Gupta, Ar, Appeared On Behalf Of The Appellant. Shri Prabir Gupta Choudhury, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 26, 2024 Date Of Pronouncing The Order : May 03, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Addition Of Rs.18,85,520/- Made By The Assessing Officer U/S 69C Of The Act On Account Of Bogus Purchases. 3. The Brief Facts Of The Case Are That The Assessee Firm Is Involved In The Business Of Spare Parts Of The Machinery. The Assessee Firm For The Year Under Consideration Filed Its Return Of Income Declaring A Total Income Of Rs.45,150/-. The Said Return Was Processed U/S 143(1) Of The

Section 143(1)Section 147Section 250Section 271(1)(c)Section 69C

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

Gurjant Singh, Jaipur vs. PCIT-2, Jaipur

In the result, the appeal of the assessee is allowed

ITA 356/JPR/2023[2018-19]Status: DisposedITAT Jaipur03 May 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S. K.Gogra (C.A.)For Respondent: Shri Anup Singh (Addl.CIT) a
Section 142(1)Section 143(3)Section 263Section 270ASection 271ASection 44ASection 68

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk0 ,l- lhrky{eh

Mr Homi R. Cooper, Mumbai Suburban vs. Assistant Commissioner on Income Tax, Circle 19(2), Mumbai

In the result, the appeal by the assessee for the assessment year 2016-

ITA 3929/MUM/2023[2016-2017]Status: DisposedITAT Mumbai03 May 2024AY 2016-2017

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Satish ModyFor Respondent: Shri P. D. Chougule
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 274Section 80G

assessment years 2014-15 and 2016-17. 2. Since in both appeals, the assessee is challenging the levy of penalty under section 271(1)(c) of the Act, which arises out of a similar factual matrix, Mr. Homi R. Cooper. ITA no. 3929/Mum/2023 therefore these appeals were heard together ... appeal- A.Y. 2014-15 3. The only grievance of the assessee, in the present appeal, is against the levy of penalty under section 271(1)(c) of the Act. 4. The brief facts of the case as emanating from the record are: For the year under consideration, the assessee filed

Mr Homi R. Cooper, Mumbai vs. Assistant Commissioner of Income Tax Circle, 19(2), Mumbai

In the result, the appeal by the assessee for the assessment year 2016-

ITA 3928/MUM/2023[2014-2015]Status: DisposedITAT Mumbai03 May 2024AY 2014-2015

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Satish ModyFor Respondent: Shri P. D. Chougule
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 274Section 80G

assessment years 2014-15 and 2016-17. 2. Since in both appeals, the assessee is challenging the levy of penalty under section 271(1)(c) of the Act, which arises out of a similar factual matrix, Mr. Homi R. Cooper. ITA no. 3929/Mum/2023 therefore these appeals were heard together ... appeal- A.Y. 2014-15 3. The only grievance of the assessee, in the present appeal, is against the levy of penalty under section 271(1)(c) of the Act. 4. The brief facts of the case as emanating from the record are: For the year under consideration, the assessee filed

Benny Impex Pvt. Ltd., New Delhi vs. DCIT Circle 4(2), New Delhi

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

ITA 603/DEL/2024[2016-17]Status: DisposedITAT Delhi03 May 2024AY 2016-17

Bench: Shri Shamim Yahya & Shri Sudhir Pareek

For Appellant: Shri O.P. Aggarwal, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 14ASection 271(1)(c)Section 40Section 40A(3)Section 43B

Delhi and ITAT upheld the disallowance on account of addition u/s 40A(3) of Rs.2,25,148/-. AO levied the penalty under section 271(1)(c) of the Income-tax Act, 1961 (for short ‘the Act’) amounting to Rs.1,72,227/-. Ld. CIT (A) confirmed the penalty order. 4. Against ... Upon careful consideration, we find that in this case, assessee does not deserve to be visited with the rigours of penalty under section 271(1)(c) of the Act. The case laws cited above duly supports the case of the assessee. Furthermore, the conduct of the assessee is not contumacious

Computer Modelling Group Limited, Canada vs. ACIT International Taxation Circle 1(2)(1), New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2091/DEL/2023[2020-21]Status: DisposedITAT Delhi03 May 2024AY 2020-21

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

That, on the facts and the circumstances of the case and in law, the Ld. AO has erred in initiating penalty under section 271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order ... hereby allowed. Ground No. 9 in AY 2012-13 relating to initiation of penalty 20. proceedings under section 271(1)(c), ground No. 7 in AY 2019-20 and ground No. 6 in AY 2020-21 relating to initiation of penalty proceedings under section 270A are premature in nature

Computer Modelling Group Limited, Canada vs. DCIT Circle International Taxation 1(2)(1), New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2090/DEL/2023[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

That, on the facts and the circumstances of the case and in law, the Ld. AO has erred in initiating penalty under section 271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order ... hereby allowed. Ground No. 9 in AY 2012-13 relating to initiation of penalty 20. proceedings under section 271(1)(c), ground No. 7 in AY 2019-20 and ground No. 6 in AY 2020-21 relating to initiation of penalty proceedings under section 270A are premature in nature

Pushpa Joshi, Uttar Pradesh vs. AO Ward 5(2)(4), Gautam Budh Nagar

ITA 901/DEL/2022[2011-12]Status: DisposedITAT Delhi03 May 2024AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2011-12 Pushpa Joshi Vs. Ao, Ward5(2)(4) D-170 Sector-27, Noida Gautam Budh Uttar Pradesh 201 301 Nagar Pan Aeepj0375H Uttar Pradesh (Appellant) (Respondent)

For Appellant: Shri Sanjeev Jain, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 142(1)Section 147Section 148Section 234ASection 271(1)(c)

Income Tax Act, 1961 and charging interest under section 234A and 234B issued notice of demand and challans and issue penalty notice under section 271(1)(c) of the Income Tax Act, 1961 for furnishing inaccurate/concealed the particulars of his income separately. 2. Brief facts of case are that

Computer Modelling Group Limited, Canada vs. ACIT, Circle-1(2)(1), Int. Taxation, New Delhi

In the result, all the four appeals of the assessee for AY 2012-13,

ITA 2305/DEL/2022[2019-20]Status: DisposedITAT Delhi03 May 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

Section 143(3)Section 144CSection 144C(13)Section 153Section 234ASection 234BSection 250Section 271(1)(c)Section 44B

That, on the facts and the circumstances of the case and in law, the Ld. AO has erred in initiating penalty under section 271(1)(c) of the Act. Assessment Year 2019-20 1. That, on the facts and in the circumstances of the case and in law, the order ... hereby allowed. Ground No. 9 in AY 2012-13 relating to initiation of penalty 20. proceedings under section 271(1)(c), ground No. 7 in AY 2019-20 and ground No. 6 in AY 2020-21 relating to initiation of penalty proceedings under section 270A are premature in nature

Umanath Finvest Pvt. Ltd., Delhi vs. ITO, Ward-27(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2988/DEL/2019[2006-07]Status: DisposedITAT Delhi03 May 2024AY 2006-07

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

For Appellant: NoneFor Respondent: Sh. Vivek K. Upadhyay, Sr. DR
Section 271Section 271(1)(c)Section 274

been raised by the assessee: “1. That the Income Tax officer have erred in levying a penalty of Rs. 70,68,600/- under section 271(1)(c) of Income Tax Act, 1961. 2. That the levy of penalty confirmed by the Ld CIT (A)-28, New Delhi u/s 271(1 ... Manjunatha Cotton and Ginning Factory: 359 ITR 565 held that notice under section 274 should specifically state the grounds mentioned in section 271(1)(c) of the Act, i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form where

Shyam Sunder Jindal, New Delhi vs. ACIT, Circle- 30, Muzaffarnagar

In the result, appeal of the assessee is allowed

ITA 3866/DEL/2017[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra & Asstt. Years: 2012-13

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Dharamvir Singh, CIT-DR
Section 143(3)Section 271(1)(c)

Assessing Officer (“AO”) on account of accruals/interest on foreign bank account balance in alleged HSBC Bank, Geneva and confirmed the penalty under section 271(1)(c) of the Income Tax Act, 1961 (the “Act”) for concealment of particulars of income/furnishing inaccurate particulars of income qua the said addition AND respectively ... favour. 9. In the result, appeal of the assessee is allowed. 10. The appeal relates to levy of concealment penalty under section 271(1)(c) of the Act qua the addition of Rs. 3,87,075/- made by the Ld. AO and maintained by the Ld. CIT(A) on account

Shyam Sunder Jindal, New Delhi vs. ACIT, New Delhi

In the result, appeal of the assessee is allowed

ITA 5450/DEL/2016[2012-13]Status: DisposedITAT Delhi03 May 2024AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra & Asstt. Years: 2012-13

For Appellant: Shri Rohit Jain, AdvocateFor Respondent: Shri Dharamvir Singh, CIT-DR
Section 143(3)Section 271(1)(c)

Assessing Officer (“AO”) on account of accruals/interest on foreign bank account balance in alleged HSBC Bank, Geneva and confirmed the penalty under section 271(1)(c) of the Income Tax Act, 1961 (the “Act”) for concealment of particulars of income/furnishing inaccurate particulars of income qua the said addition AND respectively ... favour. 9. In the result, appeal of the assessee is allowed. 10. The appeal relates to levy of concealment penalty under section 271(1)(c) of the Act qua the addition of Rs. 3,87,075/- made by the Ld. AO and maintained by the Ld. CIT(A) on account

Radheshyam Meena, Rajgarh vs. Income Tax Officer, Alwar

9. In view of the discussion and reasons recorded above, in the interest of justice, we hereby allow the appeal for statistical purposes, set aside the impugned order passed by Learned CIT(A)

ITA 306/JPR/2024[2014-15]Status: DisposedITAT Jaipur02 May 2024AY 2014-15

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Hanuman Singh (Adv.) &For Respondent: Shri Ajay Malik ( CIT)
Section 142(1)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Jh jkBkSM+ deys'k

Income Tax Officer -Ward-41(2)(4), Mumbai, Kautilya Bhawan, G Block, Bkc, Bandra East vs. Pushpadevi Santkumar Tola, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 2762/MUM/2023[2009-10]Status: DisposedITAT Mumbai02 May 2024AY 2009-10

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri S.L. JainFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 147Section 250Section 271(1)(c)

Centre, Delhi [“learned CIT(A)”], for the assessment year 2009-10, which in turn arose from the penalty order dated 23/03/2018 passed under section 271(1)(c) of the Act. 2. The present appeal is delayed by 33 days. In the application seeking condonation of delay filed by the Revenue ... delay in filing the present appeal is condoned. 3. The only grievance of the Revenue is against the deletion of penalty levied under section 271(1)(c) of the Act. 4. We have considered the submissions of the learned DR and perused the material available on record. During the year

Binod Kumar Singh, Mumbai vs. DCIT Cen Cir 40, Mumbai

In the result, the appeal by the assessee is dismissed with the above directions

ITA 1062/MUM/2016[2003-04]Status: DisposedITAT Mumbai02 May 2024AY 2003-04

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailshri Binod Kumar Singh ‘A’ Wing, 601-602, Delphi Orchard Avenue, ……………. Appellant Hiranandani Business Park, Powai Mumbai-400076. Pan – Amxps1498L V/S Acit, Central Circle-40 6Th Floor, Aaykar Bhavan ……………. Respondent Mumbai-400020. Assessee By : None Revenue By : Shri Ashok Kumar Ambastha – Sr. Ar

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha – Sr. AR
Section 250Section 271(1)(c)

learned Commissioner of Income Tax (Appeals)-49, Mumbai [“learned CIT(A)”], which in turn arose from the penalty order dated 25/03/2014 passed under section 271(1)(c) of the Act, for the assessment year 2003-04. Shri Binod Kumar Singh 2. When the present appeal was called for hearing neither

Avr Textile Private Limited, Coimbatore vs. ACIT, Corporate Circle-2, Coimbatore

The appeal stand allowed for statistical purposes

ITA 358/CHNY/2024[2013-14]Status: DisposedITAT Chennai01 May 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.358/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2013-14) M/S Avr Textile Private Ltd. Acit Sf No.511/1, Kalpatharu Road Corp. Circle 2 बनाम/ Vs. Behind Lmw Unit-11 Coimbatore – 641 018 Kollupalayam, Coimbatore- 641 659 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacca-4473-A (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri G. Tarun (Advocate) – Ld. Ar " थ"कीओरसे/Respondent By : Shri Arv Srinivasan (Addl. Cit) – Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 29-04-2024 घोषणा की तारीख /Date Of Pronouncement : 01-05-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013- 14 Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 14-12-2023 In The Matter Of Penalty Levied By Ld. Ao U/S 271(1)(C) For Rs.14.53 Lacs Vide Order Dated 27-07-2018. The Assessee Failed To Make Any Representation During Appellate

For Appellant: Shri G. Tarun (Advocate) – Ld. ARFor Respondent: Shri ARV Srinivasan (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

Sh. Ramnarayan Meena, Tonk vs. ITO, Ward-Tonk, Tonk

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

ITA 259/JPR/2024[2017-18]Status: DisposedITAT Jaipur01 May 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT) a
Section 139Section 142(1)Section 144Section 144(1)(b)Section 144BSection 147Section 148Section 151Section 69

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR Mk0 ,l- lhrky{eh

DCIT, New Delhi vs. Candor Gurgaon One Reality Project Pvt. Ltd., New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1647/DEL/2021[2014-15]Status: DisposedITAT Delhi01 May 2024AY 2014-15

Bench: Shri Amit Shukla & Shri M. Balaganeshassessment Year: 2014-15

Section 234BSection 271(1)(c)Section 80Section 80I

circumstances of the case & in law, the Ld. CIT (Appeals) has erred in not adjudicating the ground on initiation of penalty proceedings under section 271(1)(c) of the Act.” 4. We have heard the rival submissions and perused the materials available on record. The assessee company is engaged

Candor Gurgaon One Reality Projects Private Limited, Mumbai vs. ACIT Circle-5(2), New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1635/DEL/2020[2014-15]Status: DisposedITAT Delhi01 May 2024AY 2014-15

Bench: Shri Amit Shukla & Shri M. Balaganeshassessment Year: 2014-15

Section 234BSection 271(1)(c)Section 80Section 80I

circumstances of the case & in law, the Ld. CIT (Appeals) has erred in not adjudicating the ground on initiation of penalty proceedings under section 271(1)(c) of the Act.” 4. We have heard the rival submissions and perused the materials available on record. The assessee company is engaged

Sewa Developers Pvt. Ltd., Ghaziabad vs. DCIT, Circle- 23(2), New Delhi

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

ITA 4067/DEL/2019[2012-13]Status: DisposedITAT Delhi01 May 2024AY 2012-13

Bench: Shri Amit Shukla & Shri M. Balaganeshassessment Year: 2012-13

Section 271(1)Section 271(1)(c)Section 68

1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI