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“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)

Deputy Commissioner of Income Tax, Central Circle-1(4), Hyderabad vs. Pioneer Builders, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 64/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

Deputy Commissioner of Income Tax, Central Circle-1(4), Hyderabad vs. Pioneer Builders, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 57/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

Deputy Commissioner of Income Tax, Central Circle-1(4), Hyderabad vs. Pioneer Builders, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 56/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

Deputy Commissioner of Income Tax, Central Circle-1(4), Hyderabad vs. Dsr Infrastructure Private Limited, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 54/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

Deputy Commissioner of Income Tax, Central Circle-1(4), Hyderabad vs. Dsr Infrastructure Private Limited, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 53/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

D S R Infrastructure Private Limited, Hyderabad vs. DCIT., Central Circle-1(4), Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 51/HYD/2024[2020-21]Status: DisposedITAT Hyderabad29 Aug 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

DCIT., Central Circle-1(4), Hyderabad vs. Dsr Infrastructure Private Limited, Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 50/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

D S R Infrastructureprivate Limited, Hyderabad vs. DCIT., Central Circle- 1(4), Hyderabad

In the result, the appeals of Revenue in ITA Nos

ITA 49/HYD/2024[2019-20]Status: DisposedITAT Hyderabad29 Aug 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdiasl.

For Appellant: Shri A.V. Raghuram, Advocate for assessee at Sl.Nos.1 to 3For Respondent: Date of Hearing
Section 127Section 132Section 133ASection 142(1)Section 143(2)Section 143(3)

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

Ram Awatar Dhoot, Kolkata vs. Ward 22(4) Kolkata, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 91/KOL/2024[2015-16]Status: DisposedITAT Kolkata29 Aug 2024AY 2015-16

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.91/Kol/2024 Assessment Year: 2015-16 Ram Awatar Dhoot…...…………….....……………………....………....Appellant 29B, Rabindra Sarani Floor, Room No.10E, Kolkata-700073. [Pan: Adepd7419F] Vs. Ito, Ward-22(4), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Ram Awatar Dhoot, Self, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 27, 2024 Date Of Pronouncing The Order : August 29, 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 26.12.2023 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 Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.14,94,407/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There

Section 250Section 271(1)(c)

bogus transaction, if any, therefore, merely because the additions have been made on the basis of preponderance of probabilities, the penal provisions to section 271(1)(c) of the Act were not attracted. 5.1 The ld. DR, on the other hand, has relied upon the findings of the lower authorities ... this case, however, to establish the allegation of concealment of income/ furnishing of inaccurate particulars of income to invoke penal provisions of section 271(1)(c) of the Act, stricter proof is required, which, in our view, is missing in this case. Hence, giving the benefit of doubt

Sh. Anoop Kumar Gupta, Ajmer vs. ITO, Ward-2(1), Ajmer

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

ITA 939/JPR/2024[2014-15]Status: DisposedITAT Jaipur29 Aug 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P.C. Parwal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 271(1)(c)Section 274

dated 08.05.2024 for the assessment years 2014- 15, which in turn arise from the order dated 18.03.2019 passed under section 271(1)(c) of the Income Tax Act, 1961 (here in after “ Act”), by the ITO, Ward-1(1), Ajmer. 2. The assessee has raised the following grounds ... income. In view of the above facts and circumstances of the case, it was a fit case for imposing of penalty under section 271(1)(C) of the Income-tax Act 1961 and accordingly a penalty of Rs.2,57,261/- was imposed under section 271(1)(c) of the Income

Virendrakumar Brijratan Mohatta, Mumbai vs. JCIT-19(2), Mumbai

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

ITA 3634/MUM/2024[1999-2000]Status: DisposedITAT Mumbai29 Aug 2024AY 1999-2000

Bench: Ms. Padmavathy S & Shri Sandeep Singh Karhail

For Appellant: Shri Ravikanth PathakFor Respondent: Shri Surendra Meena, Sr. DR
Section 143(3)Section 147Section 250Section 271(1)(c)Section 274Section 69A

Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], which in turn arose from the penalty order passed under section 271(1)(c) of the Act, for the assessment year 1999-00. 2. In this appeal, the assessee has raised the following grounds: - 1 ... undisclosed income of the assessee from an undisclosed bank account in HSBC Bank, Geneva, Switzerland. In the meanwhile, notice under section 274 r/w section 271(1)(c) of the Act was issued on 23/01/2015 and served on the assessee. Vide order dated 27/07/2015 passed under section 271(1

Sanjeev Kumar, Utter Pradesh vs. DCIT, Central Circle -14, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2017/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri M. Balaganesh & Shri Anubhav Sharmasanjeev Kumar, Vs. Dcit, Ram Kutir, D. M. Central Circle-14, Colony, Road, New Delhi Bulandshahr, Uttar Pradesh (Appellant) (Respondent) Pan: Abbpk0132H

For Appellant: Shri Madhav Kapur, AdvFor Respondent: Shri t. James Singson, CIT DR
Section 271(1)Section 271(1)(c)Section 274

materials available on record. At the outset the ld.AR placed on record the copy of penalty show cause notice u/s 274 read with section 271(1)(c ) of the Act wherein, we find that the ld. AO had not struck off the inappropriate portion as to whether the assessee ... case of a mandatory provision of law which is conceived not only in individual interest but also in the public interest". 190. Here, section 271(1)(c) is one such provision. With calamitous, albeit commercial, consequences, the provision is mandatory and brooks no trifling with or dilution. For a further

Borgwarner Emissions Systems India Private Limited, New Delhi vs. DCIT, Circle-4(2), Delhi

Appeal is allowed

ITA 2015/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 234BSection 271(1)(c)Section 92C

addition thereto, directions were issued to charge interest under sections 234Aa, 234B, 234C and 234D. Even penalty proceedings under section 271(1)(c) were also directed to be initiated separately. The two additions pertain to international transactions regarding: (i) payment for Business support service (BSS); (ii) Payment for Technical support

Chl Limited, New Delhi vs. ACIT, Circle-6(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 8776/DEL/2019[2012-13]Status: DisposedITAT Delhi29 Aug 2024AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharmam/S. Chl Ltd, Vs. Acit, Hotel The Surya, Circle-16(1), New Friends Colony, New Delhi New Delhi (Appellant) (Respondent) Pan:Aaacc2587M

For Appellant: Shri Satish Khosla, AdvFor Respondent: Shri Piyush Tripthi, Sr. DR
Section 143(3)Section 271(1)Section 271(1)(c)Section 274

materials available on record. At the outset the ld.AR placed on record the copy of penalty show cause notice u/s 274 read with section 271(1)(c ) of the Act wherein, we find that the ld. AO had not struck off the inappropriate portion as to whether the assessee ... case of a mandatory provision of law which is conceived not only in individual interest but also in the public interest". 190. Here, section 271(1)(c) is one such provision. With calamitous, albeit commercial, consequences, the provision is mandatory and brooks no trifling with or dilution. For a further

Rukmani Wires Pvt Ltd, New Delhi vs. DCIT Circle-21(2), New Delhi

In the result, the appeal of the assessee is partly allowed

ITA 5481/DEL/2019[2015-16]Status: DisposedITAT Delhi29 Aug 2024AY 2015-16

Bench: Shri M. Balaganesh & Shri Vimal Kumarrukmani Wires Pvt. Ltd, Vs. Dcit, G-1087, Dsiidc Industrial Circle-1(2), Complex Area, New Delhi New Delhi (Appellant) (Respondent) Pan:Aaccr7552F

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 10Section 115QSection 143(3)Section 18Section 271(1)Section 46ASection 48

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL

Soma Textiles & Industries Ltd., Ahmedabad vs. The DCIT, Circle-4(1)(1), Ahmedabad

In the result appeal of the assessee is allowed

ITA 53/AHD/2022[2008-09]Status: DisposedITAT Ahmedabad28 Aug 2024AY 2008-09

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2008-09

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

facts of the case and elaborate submissions filed, the appellant's case does not fall within the scope of provisions of Section 271(1)(c) of the Act. Accordingly, the impugned penalty of Rs.1,43,24,576/- requires to be quashed/cancelled. 2. The appellant states that since complete details, submissions ... addition of Exchange 68,96,702 Rs.57,76,604 and Fluctuation confirmed the addition Rs.68,96,702/- 3.1 A show cause notice under Section 271(1)(c) of the Act was issued on 14.07.2017 for which the assessee replied. After taking cognisance of the reply, the Assessing Officer held that

Pramod Kumar Saraf, Kolkata vs. ITO, Ward-22(2), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 683/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.683/Kol/2024 Assessment Year: 2014-15 Pramod Kumar Saraf...…………….....……………………....………....Appellant 24, R. N Mukherjee Road, Mission Row, Kol-1. [Pan: Apkps6814F] Vs. Ito, Ward-22(2), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2024 Date Of Pronouncing The Order : August 28, 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 26.03.2024 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 Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.7,10,447/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There Was Large Scale Price Rigging Of Certain Scrips, Whereby, The Bogus Long-Term

Section 250Section 271(1)(c)

bogus transaction, if any, therefore, merely because the additions have been made on the basis of preponderance of probabilities, the penal provisions to section 271(1)(c) of the Act were not attracted. 5.1 The ld. DR, on the other hand, has relied upon the findings of the lower authorities ... this case, however, to establish the allegation of concealment of income/ furnishing of inaccurate particulars of income to invoke penal provisions of section 271(1)(c) of the Act, stricter proof is required, which, in our view, is missing in this case. Hence, giving the benefit of doubt

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1). Kolkata., Kolkata

In the result, both the appeals in ITA Nos

ITA 974/KOL/2023[2015-16]Status: DisposedITAT Kolkata28 Aug 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

Commissioner of Income-tax (Appeals) [learned CIT (A)] even dated 21.07.2023. The penalties were levied by ACIT Circle 1 (1), Kolkata under section 271(1)(c) & 271AAB of the Act for A.Y. 2014-15 & 2015-16 respectively, vide even order dated 29th June, 2017. 02. Firstly, we take ... confirming the penalty levied by ITA Nos. 973 & 974/KOL/2023 SVM Cera Private Limited; A.Ys. 2014-15 & 2015-16 the learned Assessing Officer under Section 271(1)(c) of the Act for A.Y. 2014-15. 04. The learned counsel for the assessee vehemently argued referring to the written submission

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1), Kolkata

In the result, both the appeals in ITA Nos

ITA 973/KOL/2023[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

Commissioner of Income-tax (Appeals) [learned CIT (A)] even dated 21.07.2023. The penalties were levied by ACIT Circle 1 (1), Kolkata under section 271(1)(c) & 271AAB of the Act for A.Y. 2014-15 & 2015-16 respectively, vide even order dated 29th June, 2017. 02. Firstly, we take ... confirming the penalty levied by ITA Nos. 973 & 974/KOL/2023 SVM Cera Private Limited; A.Ys. 2014-15 & 2015-16 the learned Assessing Officer under Section 271(1)(c) of the Act for A.Y. 2014-15. 04. The learned counsel for the assessee vehemently argued referring to the written submission

Manjudevi Ranjitlal Jain, Mumbai vs. Income Tax Officer Ward 27(2)(1), Mumbai

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

ITA 2932/MUM/2024[2011-12]Status: DisposedITAT Mumbai28 Aug 2024AY 2011-12

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri. Himanshu GandhiFor Respondent: Shri R.R. Makwana, Sr. DR
Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 234ASection 250Section 271(1)(b)Section 69A

facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming initiation of penalty proceedings under section 271(1)(b) and 271(1)(c) of the Income Tax Act, 1961. 6. Appellant craves leave to add further grounds or to amend or alter the existing