“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)

Guntupalli Nageswara Rao, Ibrahimpatnam vs. Income Tax Officer, Ward 1(1), Vijayawada

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 378/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 147Section 148Section 148ASection 149(1)(b)Section 250Section 271(1)(c)Section 8Section 80CSection 80DSection 80E

under section 147 of the Income-Tax Act, 1961 (for short, “the Act”), dated 12.05.2023 for the A.Y. 2016-17 and under section 271(1)(c) of the Act, dated 30.01.2024 for the A.Y. 2016-17. 2. As the captioned appeals are inextricably interlinked and interwoven, therefore, they are being ... arises from the order passed by the CIT(A), dated 20.03.2025, which in turn arises from the order passed by the AO under section 271(1)(c) of the Act dated 30.01.2024. 21. At the threshold, we find that there is a delay of 7 days in filing the present

Shahanshah Dal Mill, Bhopal vs. ITO-5(3), Bhopal

Appeal is dismissed

ITA 335/IND/2025[2015-16]Status: DisposedITAT Indore27 Feb 2026AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 143(2)Section 147Section 40A(2)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI

M/S Pumarth Infrastructure Private Limited, Indore vs. The Asstt Commissioner of Income Tax Circle - 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 766/IND/2024[2009 -2010]Status: DisposedITAT Indore27 Feb 2026

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 132Section 153ASection 271(1)(c)Section 40A(3)

Private Limited ITA Nos. 766/Ind/2024, 757/Ind/2024, 765/Ind/2024 AYs: 2009-10 to 2011-12 “Additional Ground No. 1: Whether the penalty proceedings initiated under Section 271(1)(c) of the Income-tax Act, 1961, are without jurisdiction and bad in law, as the Assessing Officer failed to record any prima facie

M/S Pumarth Infrastructure Private Limited, Indore vs. The Asstt Commissioner of Income Tax Circle 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 765/IND/2024[2011-12]Status: DisposedITAT Indore27 Feb 2026AY 2011-12

Section 132Section 153ASection 250Section 271(1)(c)Section 40A(3)

below the additional grounds of first AY 2009-10 for an immediate reference: "Additional Ground No. 1: Whether the penalty proceedings initiated under Section 271(1)(c) of the Income-tax Act, 1961, are without jurisdiction and bad in law, as the Assessing Officer failed to record any prima facie

M/S Pumarth Infrastructure, Indore vs. The Asst Commissioner If Income Tax Circle 4(1), Aaykar Bhawan, Indore

Appeals are allowed for statistical purposes

ITA 757/IND/2024[2010 -11]Status: DisposedITAT Indore27 Feb 2026

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 132Section 153ASection 271(1)(c)Section 40A(3)

Kapil Khandelwal, Bareilly, Uttar Pradesh vs. Asst. Commissioner of Income Tax, Circle-I, Bareilly, Uttar Pradesh

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

ITA 335/LKW/2025[2015-16]Status: DisposedITAT Lucknow27 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 Kapil Khandelwal, Vs. Asstt. Commissioner Of 56, Moar Kothi, Gangapur, Bareilly Income Tax, Circle-I, Bareilly Pan: Aiypk4908M (Appellant) (Respondent) Assessee By: Sh. P.K. Kapoor, C.A. Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 27.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Under Section 250 Of The Income Tax Act, 1961, Wherein The Ld. Cit(A) Has Confirmed The Penalty Levied Upon The Assessee Under Section 271(1)(C) By The Ld. Ao On 17.03.2022 & Dismissed The Appeal Of The Assessee For The A.Y. 2015-16. The Grounds Of Appeal Are As Under: - “1. Because Requisite Satisfaction For Levy Of Penalty U/S 271(1)(C) If The Income Tax Act 1961 Was Not Recorded In The Regular Assessment Order Dated 22.12.2017 Passed A/S 100%, Therefore, Penalty Proceedings Got Wholly Vitiated & Consequently, The Id. "Cit(A)" Ought To Have Quashed The Penalty Order Dated 17.03.2022, Being Illegal, Bad-In-Law & Without Jurisdiction 2. Because The Show Cause Notice For Levy Of Penalty Under Section 271(1)(C) Of The Act Did Not Specify Under Which Limb Penalty Was Sought To Be Imposed I.E.. Whether On Account Of Concealment Of Income Or For Furnishing Inaccurate Particulars Of Income & Consequently, The Penalty Order Dated 17.03.2022 Passed By Faceless Assessing Officer Deserved To Be Quashed.

For Appellant: Sh. P.K. Kapoor, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 10(38)Section 250Section 271(1)(c)

under section 250 of the Income Tax Act, 1961, wherein the ld. CIT(A) has confirmed the penalty levied upon the assessee under section 271(1)(c) by the ld. AO on 17.03.2022 and dismissed the appeal of the assessee for the A.Y. 2015-16. The grounds of appeal ... penalty order dated 17.03.2022, being illegal, bad-in-law and without jurisdiction 2. BECAUSE the show cause notice for levy of penalty under section 271(1)(c) of the Act did not specify under which limb penalty was sought to be imposed i.e.. whether on account of concealment

Gopal Chandra Bagui, Uluberia vs. ITO, Ward 46(1), Range 146, Kolkata

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

ITA 3013/KOL/2025[2015-16]Status: DisposedITAT Kolkata27 Feb 2026AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Gopal Chandra Bagui………….…..………………….……….……….……Appellant Uluberia, Jagadishpur, Howrah-711315. [Pan: Adwpb9619F] Vs. Ito, Ward-46(1), Kolkata..…...……...…………………….....……...…..…..Respondent Appearances By: Shri Biswajit Sarkar, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 24, 2026 Date Of Pronouncing The Order : February 27, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.06.2025 Of The Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Are That The Assessee Did Not File His Return Of Income For The Assessment Year 2015-16. As Per Information Available With The Department, The Assessee Has Sold An Immovable Property For A Sale Consideration Of Rs.50,14,000/-. Order U/S 148A(D) Was Passed & Notice U/S 148 Of The Act Was Issued To The Assessee. During The Assessment Proceedings, The Assessee Did Neither Comply Nor Made Any Submission. The Assessing Officer Completed The Assessment U/S 144 R.W.S 147 Assessing Total Income Of Rs.50,14,000/- & A Penalty Proceedings U/S 271(1)(C) Of The Act Was Initiated.

Section 144Section 148Section 148ASection 250Section 271(1)(c)

आयकर अपीलीय अधिकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH KOLKATA Before Shri Rajesh Kumar, Accountant

Venkata Ramana Murthy Bollapragada, Hyderabad vs. ITO, Ward-13(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1961/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1961/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Venkata Ramana Murthy Vs. Income Tax Officer, Bollapragada, Ward-13(1), Hyderabad. Hyderabad. Pan: Abmpb7770R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/02/2026 घोषणा की तारीख/Date Of 26/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 27/10/2025, Which In Turn Arises From The Order Passed By The Additional/Joint Commissioner Of Income Tax, Range-13, Hyderabad Under Section 271D Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/06/2022 For The Assessment Year

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 143(3)Section 269SSection 271DSection 274Section 54F

regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could ... regarding penalty proceeding under Section 271E of the Act, though in that order the Assessing Officer wanted penalty proceeding to be initiated under Section 271(1)(c) of the Act. Thus, insofar as penalty under Section 271E is concerned, it was without any satisfaction and, therefore, no such penalty could

Virchow Petrochemical Private Limited, Hyderabad vs. ACIT., Central Circle-8(1), Hyderabad

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16

For Appellant: Shri M.V. Prasad, CAFor Respondent: Ms. U. Mini Chandran

Section 143(3)Section 147Section 148Section 250

about the disposal of its appeal by the CIT(A) only when it was in receipt of a show cause notice (SCN) under section 271(1)(c) of the Act, dated 11/07/2025, which was dropped at its new email Id that was used for filing the latest return of income ... appeal by the CIT(A), and had gathered about the same only when a "SCN", dated 11/07/2025 purporting imposition of penalty under section 271(1)(c) of the Act on 11/07/2025 was dropped in its new email account, i.e., "accounts@virchowpetro.com”, therefore, in our view the same explain the reason leading

Reema Agarwal, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

ITA 353/HYD/2021[2014-15]Status: DisposedITAT Hyderabad26 Feb 2026AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.353/Hyd./2021

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 111ASection 139(1)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Chitrakoot Tradeline Private Limited, Kolkata vs. National Faceless Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed

ITA 193/KOL/2025[2012-13]Status: DisposedITAT Kolkata26 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Chitrakoot Tradeline Private Limited National Faceless Assessment C/O Agarwal Vishwanath & Centre, Associates, 2Nd Floor, E-Ramp, Jawaharlal Vs. 133/1/1A, S.N. Banerjee Road, Nehtru Road, New Delhi-110003 Pushkal Bhawan, 3 Rd Floor, Kolkata-700103, West Bengal (Appellant) (Respondent) Pan No. Aabcc3130H Assessee By : S/Shri Deep Agarwal & Shubhankar Ghosh, Ars Revenue By : Shri Santanu Ghosh, Dr Date Of Hearing: 22.01.2026 Date Of Pronouncement: 26.02.2026

For Appellant: S/Shri Deep Agarwal &For Respondent: Shri Santanu Ghosh, DR

Section 142(1)Section 143(3)Section 144BSection 68

premium remains unsubstantiated. The addition under section 68 is therefore sustained. 5.5 The appellant asserts that the initiation of penalty proceedings under section 271(1)(c) is unjustified, as there was no concealment of income or furnishing of inaccurate particulars. The initiation of penalty proceedings under section 271(1)(c ... burden of proof regarding the identity, creditworthiness, and genuineness of the share capital and share premium transactions. The initiation of penalty proceedings under section 271(1)(c) is valid and will be adjudicated separately. The appeal is dismissed. The assessment 5.7 stands confirmed.” 5. After hearing the rival contentions

Karur Sree Rama Trading Pvt.Ltd., Karur vs. ITO, Circle-191), Trichy

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

ITA 3841/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3841/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Karur Sree Rama Trading Pvt. Ltd., Vs. The Income Tax Officer, S.F. No. 2262, Pari Nagar, Chinna Circle 1(1), Andan Koil Road, Karur 639 001. Trichy. [Pan:Aabfs8790C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 26.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13 Passed Under Section 147/271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT

Section 144Section 147Section 271(1)(c)Section 274

outset, the ld. AR Shri Y. Sridhar, F.C.A. submits that the ld. CIT(A) erred in upholding the penalty levied under section 271(1)(c) of the Act on the erstwhile partnership firm even though the firm had ceased to 2 I.T.A. No.3841/Chny/25 exist after conversion into a company w.e.f ... such reassessment is void and therefore, the penalty based on it is also invalid. Further, the ld. AR submits that as per section 271(1)(c) of the Act, the Assessing Officer requires to record proper satisfaction during the assessment and argued that a vague or mechanical initiation without proper

Amber Corporation, Kalyan vs. ITO Ward 3(1), Kalyan, Thane

In the result the Assessee’s Appeal is allowed

ITA 8373/MUM/2025[2010-2011]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-2011

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11

For Appellant: Shri. Hitesh ShahFor Respondent: Shri. Surendra Mohan (SR. DR.)

Section 250Section 271Section 271(1)(c)Section 274

hereby requested to appear before the undersigned to show why an order imposing a penalty on you should not be made under section 271(1)(c) of the 1.T. Act, 1961. If you do not wish to avail yourself of this opportunity of being heard in person on through ... writing within seven days from the date of receipt of this notice, which will be considered before any such is made under section 271(1)(c). (SHIVAJI B. GHODE) Dy. Commissioner of Income-tax Circle-3, Kalyan. 7. The validity/legality of such kind of notice as involved in this case

DCIT 4(2)(1) Mumbai, Mumabi vs. Maharaja Builders Private Limited, Mumbai

Accordingly, the Cross Objections filed by the assessee are dismissed as withdrawn

ITA 8156/MUM/2025[2017-18]Status: HeardITAT Mumbai26 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 8155/Mum/2025 (Assessment Year: 2016-17) & 2. Ita No. 8156/Mum/2025 (Assessment Year: 2017-18) Dcit 4(2)(1) Maharaja Builders Room No. 640, Aayakar Private Limited, Bhavan, M. K. Road, Vs. 4A Vikas Centre S. Churchgate, Mumbai – V. Road, Santacruz 400 020 West, Mumbai – 400 054 Pan/Gir No. Aaacm7464M (Applicant) (Respondent) 3. C.O. No. 60/Mum/2026 (Assessment Year: 2016-17) & 4. C.O. No. 61/Mum/2026 (Assessment Year: 2017-18) Maharaja Builders Dcit 4(2)(1) Private Limited, Room No. 640, 4A Vikas Centre S. V. Vs. Aayakar Bhavan, M. Road, Santacruz West, K. Road, Churchgate, Mumbai – 400 054 Mumbai – 400 020 Pan/Gir No. Aaacm7464M (Applicant) (Respondent) & Co No. 61 & 68/Mum/2026 Maharaja Builders Private Limited

Section 127Section 253Section 270ASection 271(1)(c)

penalty order was passed by the Deputy Commissioner of Income Tax, Central Circle-1, Nashik dated 26.03.2022 under section 271(1)(c) of the Income-tax Act, 1961.For A.Y. 2017-18, the penalty order was passed by the Deputy Commissioner of Income Tax, Central Circle-1, Nashik dated 26.03.2022 under

DCIT 4(2)(1) Mumbai, Mumbai vs. Maharaja Builders Private Limited, Mumbai

Accordingly, the Cross Objections filed by the assessee are dismissed as withdrawn

ITA 8155/MUM/2025[2016-17]Status: HeardITAT Mumbai26 Feb 2026AY 2016-17

Section 127Section 253Section 270ASection 271(1)(c)

M/S.Allied Digital Services Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 1(3), Mumbai

In the result the Assessee‟s Appeal is allowed

ITA 8147/MUM/2025[2010-11]Status: DisposedITAT Mumbai26 Feb 2026AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2010-11 M/S. Allied Digital Services Deputy Commissioner Of Limited, Income Tax, Central 808, 8Th Floor, Mafatlal Centre, Circile 1(3), 905,9Th Floor, Nariman Point, Vs. Mumbai – 400021. Old Cgo Building, Pan – Aaaca5509K Pratishtha Bhavan, M.K. Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Ms. Vinita Shah, Ld. A.R. Revenue By : Shri Surendra Mohan, Sr. D.R. Date Of Hearing : 12.02.2026 Date Of Pronouncement : 26.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short „The Act‟) For The A.Y. 20101-11. 2. In The Instant Case, The Ao Vide Assessment Order Dated 28.03.2013 Under Section 143 (3) R.W.S. 153(A) Of The Act Has Made The Additions Of Rs.5,35,91,882/- & Rs.1,25,66,049/- On Account Of Disallowances Under Section 69C Of The Act & Section 2 M/S. Allied Digital Services Limited

For Appellant: Ms. Vinita Shah, Ld. A.RFor Respondent: Shri Surendra Mohan, Sr. D.R

Section 143Section 2Section 250Section 271(1)(c)Section 274Section 69C

while making the addition of Rs.5,35,91,882/- also recorded the satisfaction in the assessment order for initiation of penalty proceedings under Section 271(1)(c) of the Act for furnishing of inaccurate particulars of income and thereby, canceling the said income. The AO simultaneously also issued a notice ... following limb: “Concealing particulars of income OR furnishing inaccurate particulars of such income”. 3. The AO vide penalty order dated 25.02.2019 under Section 271(1)(c) r.w.s. 274 of the Act, ultimately levied the penalty of Rs.18,21,588/- @ 100% being amount of tax evaded on the income of Rs.54

DCIT(It)-4(1)(2), Mumbai vs. Arun Madhavachari Rangachari, Mumbai

ITA 3814/MUM/2025[2011-12]Status: DisposedITAT Mumbai26 Feb 2026AY 2011-12

For Appellant: Shri Gaurav KabraFor Respondent: Shri Ajay Chandra, CIT-DR

Section 250Section 254Section 9(1)(vii)

ITA No.3814/MUM/2025 (Assessment Year: 2011-12) IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV

Tirmula Surya Kumari, Srikakulam vs. Income Tax Officer, Ward-1, Srikakulam

In the result, the appeal of the assessee is allowed

ITA 745/VIZ/2025[2012-13]Status: DisposedITAT Visakhapatnam25 Feb 2026AY 2012-13

Section 271(1)(c)

2 ITA No.745/Viz/2025 Tirumala Surya Kumari Income Tax Act, 1961 (“the Act”), dated 07.05.2024, pertaining to the assessment year 2012

Chandrakant Patel, Ahmedabad vs. The ITO, Ward-3(3)(6), Ahmedabad

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

ITA 1468/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2011-12

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(3)Section 148Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil

Jaswant N. Soni, Ahmedabad vs. The Income Tax Officer, Ward-1, Intl. Taxn., Ahmedabad

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

ITA 1372/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamble&

Section 143(2)Section 143(3)Section 144Section 144C(5)Section 147Section 148Section 271(1)(c)Section 271FSection 69

rendered academic and are not adjudicated. Accordingly, ITA No. 114/Ahd/2023 is allowed. Penalty Appeals – Sections 271(1)(c) and 271F of the Act 11. In view of the above, the penalty levied u/s 271(1)(c) & 271F of the Act does not survive and is hereby deleted