“Section 271(1)”

Section References (mined)Section 271Section 271(1)5,698 judgments

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

Leading authorities on Section 271(1)

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)

Seth Badri Prasad Ummedi Devi Paropkari Trust, Jaipur vs. Income Tax Officer (Exemption), Jaipur

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

ITA 1529/JPR/2024[2011-12]Status: DisposedITAT Jaipur24 Mar 2025AY 2011-12

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

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-VH a

Section 12ASection 144Section 148Section 250Section 271(1)(c)

Badri Prasad Ummedi Devi Paropkari Trust not be levied in its case. He further informed that in the annexure of this notice under section 271(1)(c) it has been mentioned that the Id. CIT(A) has dismissed the appeal of the assessee vide DIN and order no. ITBA/NFAC/S/250/2023-24/1054066417(1 ... dated 30/06/2023 for AY 2011-12 which was online downloaded by abovenamed Arvind K. Khandelwal CA and also a show cause notice under section 271(1)(c) of the I.T. Act for AY 2011-12 dated 18/11/2024. 6. I further say that the above named person, namely, Arvind K Khandelwal

Devendra Kumar Jain, Dehradun vs. Income Tax Officer, Dehradun

Appeal is allowed in above terms

ITA 201/DDN/2024[2016-17]Status: DisposedITAT Dehradun21 Mar 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2016-17 Vs. Income Tax Officer, Sh. Devendra Kumar Jain, 29, Rest Camp West, Dehradun Dehradun Pan :Agtpj5138R (Appellant) (Respondent) Assessee By Sh. K. K. Juneja, Adv. Department By Sh. A.S. Rana, Sr. Dr

Section 142(1)Section 271(1)(b)

/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1070305275(1), dated 13.11.2024, involving proceedings under section 271(1)(b) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. It emerges during the course of hearing that both ... learned lower authorities have levied section 271(1)(b) penalty of Rs.30,000/- in the assessee’s hands for having not complied with the corresponding section 142(1) notices issued on 21st and 14th October, 2023 and 1st January, 2024; respectively. 3. We have given our thoughtful consideration

Mantri Cosmos II Owners Welfare Association, Hyderabad vs. ACIT., Circle-6(1), Hyderabad

In the result, both the appeals of the assessee for the A

ITA 21/HYD/2025[2021-22]Status: DisposedITAT Hyderabad21 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.20 & 21/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2020-21 & 2021-22) Mantri Cosmos Ii Owners Vs. Asstt. Commissioner Of Welfare Association Income Tax, Circle 6(1) Hyderabad Hyderabad Pan:Aaeam1297J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates K Hari Prasad & K Karthik राज" व "ारा/Revenue By:: Smt.M Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 19/03/2025 घोषणा की तारीख/Pronouncement: 21/03/2025 आदेश/Order

For Appellant: Advocates K Hari Prasad and KFor Respondent: : Smt.M Narmada, CIT(DR)

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 80I

Allahabad) (35) is of no help to the revenue inasmuch as that was a case involving penalty under Section 271(1)(c) of the Act. That penalty being impossible for concealment of income Page 7 of 16 ITA Nos 20 and 21 of 2025 Mantri Cosmos II Owners Welfare Association

Mantri Cosmos II Owners Welfare Association, Hyderabad vs. ACIT., Circle-6(1), Hyderabad

In the result, both the appeals of the assessee for the A

ITA 20/HYD/2025[2020-21]Status: DisposedITAT Hyderabad21 Mar 2025AY 2020-21

For Appellant: Advocates K Hari Prasad and KFor Respondent: : Smt.M Narmada, CIT(DR)

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 80I

Deep Kothari, Usa vs. Asssistant Commissioner of Income Tax, Civic Centre New Delhi

Appeal is partly allowed

ITA 2250/DEL/2024[2014-15]Status: DisposedITAT Delhi21 Mar 2025AY 2014-15

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. Rachesh Sinha, AdvFor Respondent: Ms. Rini Handa, Sr. DR

Section 144C(13)Section 147Section 148Section 149Section 271(1)(c)Section 69

That on the facts and circumstances of the case, the AO and the DRP erred in initiating penalty proceedings under section 271(1)(c) and section 271F of the Act.” 4 Deep Kothari 4. Learned counsel very fairly submits that the assessee does not wish to press for his foregoing

Meena Gupta, Delhi vs. ACIT Central Circle-14, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1418/DEL/2024[2012-13]Status: DisposedITAT Delhi21 Mar 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Madhav Kapoor, AdvFor Respondent: Shri Amit Katoch, Sr. DR

Section 153CSection 271(1)(c)

proceedings u/s 271(1)(c) of the Act on the said disallowance of Rs 48,84,524/- without mentioning under which limb of section 271(1)(c) the penalty is being initiated. In the penalty proceedings, Page 2 of 9 [A.Y. 2012-13] Meena Gupta the Assessing Officer, being ... stated above, what emerges is as under: ********* p) Notice under Section 274 of the Act should specifically state the grounds mentioned in Section 271(1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income Page 5 of 9 [A.Y. 2012-13] Meena

ACIT, Circle- 26(2), New Delhi vs. Vodafone Idea Ltd. (Earlier Knwon As Vodafone Mobile Services Ltd.), New Delhi

ITA 8079/DEL/2018[2007-08]Status: DisposedITAT Delhi21 Mar 2025AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 1999-2000 Vs. M/S. Vodafone West Ltd. Acit, Circle-26(2), (Thereafter Merged With New Delhi Vodafone Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacf1190P (Appellant) (Respondent) With Assessment Year: 2007-08 Vs. M/S. Vodafone Idea Ltd. Acit, Circle-26(2), (Earlier Known As Vodafone New Delhi Mobile Services Ltd.), C-48, Okhla Industrial Area, Phase-2, New Delhi Pan: Aaacb2100P (Appellant) (Respondent) Assessee By Sh. Salil Kapoor, Adv. Sh. Anil Chachra, Adv. Ms. Ananya Kapoor, Adv. Department By Sh. Vijay B. Basanta, Cit(Dr) Date Of Hearing 06.03.2025 Date Of Pronouncement 21.03.2025 Order Per Satbeer Singh Godara, Jm These Revenue’S Appeals Ita No.7658/Del/2018 & 8079/Del/2018 For Assessment Years 1999-2000 & 2007-08

Section 271(1)(c)

short, the “CIT(A)”], New Delhi’s orders dated 28.09.2018 and 12.04.2017 passed in case nos. 35/17-18 and 09/15-16 involving proceedings under section 271(1)(c) and 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. 2. Heard both the parties at length. Case ... sole substantive grievance that the CIT(A) herein has erred in law and on facts in reversing the Assessing Officer’s action imposing section 271(1)(c) penalty of Rs.14,88,45,634/-; vide his lower appellate discussion reading as under: “5.4 Ground no. 2 is directed against the grievance

ACIT, Circle-26(2), New Delhi vs. Vodafone West Ltd., (Thereafter Merged With Vodafone Mobile Services Ltd.), New Delhi

ITA 7658/DEL/2018[1999-2000]Status: DisposedITAT Delhi21 Mar 2025AY 1999-2000

Section 271(1)(c)

Rsrg Devbuild P. Ltd, Indore vs. Income Tax Officer 4(1), Indore

Appeal is allowed for statistical purpose

ITA 692/IND/2024[2014-15]Status: DisposedITAT Indore20 Mar 2025AY 2014-15

Bench: Shri B.M. Biyani

Section 144Section 271(1)(c)

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

K B S Enterprises, Jaipur vs. ACIT (Circle-6), Jaipur

Appeal is allowed and both the said orders are hereby set aside

ITA 1346/JPR/2024[2012-2013]Status: DisposedITAT Jaipur20 Mar 2025AY 2012-2013

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

For Appellant: Shri Ashish Khandelwal, CAFor Respondent: Shri Gautam Singh Choudhry, JCIT-DR

Section 271(1)Section 274

year under consideration, gross receipts from civil construction work on 27-02-2015. He was served with notice u/s 274 read with section 271(1)(c ) of the Act to show cause as to why order of penalty be not passed u/s 271(1)(c ) of the Act, the reason ... income. This goes to show that the AO was not sure as to what was the actual ground of violation by the assessee. Section 271(1)(c ) has two limbs. Principles of natural justice require that the assessee should be apprised of the specific limb of the said provision, which

Saket Murarka, Sitapur vs. Income Tax Officer, Sitapur

In the result, the appeal of the assessee stands dismissed

ITA 2/LKW/2025[2012-13]Status: DisposedITAT Lucknow20 Mar 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Saket Murarka V. The Income Tax Officer Prop. M/S Murarka Brothers Sitapur Jail Road Sitapur Tan/Pan:Aaypm4558P (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 18 03 2025 Date Of Pronouncement: 20 03 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 142(1)Section 143(3)Section 147Section 148Section 271(1)(c)Section 50C(1)

Rs.4,01,822/- Total : Rs.12,08,702/- Rounded off : Rs.12,08,700/- 2.2 The AO also initiated penalty proceedings under section 271(1)(c) of the Act, separately. 3. Aggrieved, the assessee preferred an appeal before the Ld. First Appellate Authority. Subsequently, the case of the assessee was migrated

Rajeev Gupta L/H Ramesh Chandra Gupta, Kanpur vs. ITO-3(3), Kanpur

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

ITA 369/LKW/2024[2012-13]Status: DisposedITAT Lucknow20 Mar 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Rajeev Gupta V. The Income Tax Officer 3(3) Legal Heir Of Late Ramesh Kanpur Chandra Gupta 133/118, Transport Nagar Kanpur Nagar Tan/Pan:Aiypg8690G (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 18 03 2025 Date Of Pronouncement: 20 03 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 50C

after making addition of Rs.45,98,550/- under section 50C of the Act. 2.1 The AO also initiated penalty proceedings under section 271(1)(c) of the Act, separately. 3. Aggrieved, the assessee preferred an appeal before the Ld. First Appellate Authority. The case of the assessee was migrated

Gopal Ji Mishra, Lucknow vs. ITO-6(5), Lucknow

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

ITA 349/LKW/2024[2013-14]Status: DisposedITAT Lucknow20 Mar 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2013-14 Gopal Ji Mishra V. The Income Tax Officer 6(5) K-1218, Ashiana Lucknow - New Kanpur Road, Lucknow Tan/Pan:Akjpm8317M (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 18 03 2025 Date Of Pronouncement: 20 03 2025 O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 133(6)Section 142(1)Section 147Section 148Section 271(1)(c)Section 50CSection 69A

Rs.25,92,873/- Net taxable income (rounded off) : Rs.48,08,630/- 2.1 The AO also initiated penalty proceedings under section 271(1)(c) and 271F of the Act, separately. 3. Aggrieved, the assessee preferred an appeal before the Ld. First Appellate Authority. The case of the assessee was migrated

Ravi Kakkar, Mohali vs. Income Tax Officer, Mohali

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 496/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh20 Mar 2025AY 2012-13

Bench: Us, At The Outset, Both The Parties Submitted That The Issues Raised In Both The Appeals Were Identical. In View Of The Aforesaid

For Appellant: Smt. Kamakshi Mahajan, C.AFor Respondent: Shri Ved Parkash Kalia, JCIT, Sr. Dr

Section 142(1)Section 144Section 148Section 271(1)(b)

determining the total income of the assessee at Rs. 1,59,29,130/-. 6.1 The AO also initiated penalty proceedings under Section 271(1)(b) of the Act for non-compliance with the statutory notices. A show-cause notice was issued on 18.12.2019, followed by subsequent notices ... assessee failed to respond to these notices, and the AO levied a penalty of Rs. 20,000/- under Section 271(1)(b) of the Act. 7. Against the order of the Ld. AO the assessee went in appeal before the Ld. CIT(A). The CIT(A) dismissed the appeal

Ravi Kakkar, Mohali vs. Income Tax Officer National Faceless Assessment Centre, Delhi

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 495/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh20 Mar 2025AY 2012-13

Bench: Us, At The Outset, Both The Parties Submitted That The Issues Raised In Both The Appeals Were Identical. In View Of The Aforesaid

For Appellant: Smt. Kamakshi Mahajan, C.AFor Respondent: Shri Ved Parkash Kalia, JCIT, Sr. Dr

Section 142(1)Section 144Section 148Section 271(1)(b)

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

Section 143(3)

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