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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)

Harbhajansingh Bawansingh Heer, Mumbai vs. Asstt.Commissioner of Income Tax, Mumbai

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

ITA 4313/MUM/2023[2011-12]Status: DisposedITAT Mumbai08 Aug 2024AY 2011-12

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri Satyaprakash SinghFor Respondent: Shri R.R.Makwana, Sr.DR
Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 69

compliance on the part of the assessee to the aforesaid notices. Accordingly, after multiple opportunities and initiation of penalty proceedings under section 271(1)(b) of the Act, the Assessing Officer (“AO”) proceeded to complete the assessment on best judgment basis under section 144 of the Act on the basis

ITO, Ward-2(1)(3), Ahmedabad vs. M/S. Lydia Construction Pvt. Ltd., Ahmedabad

ITA 729/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad07 Aug 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: NoneFor Respondent: Shri Kamlesh Makwana, CIT DR
Section 133(6)Section 143(1)Section 148Section 271(1)(c)Section 68

added the same to ITO vs. M/s. Lydia Construction Pvt. Ltd. Asst.Year –2011-12 - 3– the assessee’s income. Penalty proceeding under Section 271(1)(c) were also initiated for filing inaccurate income particulars. 4. In appeal before CIT(A), the assessee submitted that the Assessing Officer added

Sarat Gopal Boppana, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 635/HYD/2022[2015-16]Status: DisposedITAT Hyderabad07 Aug 2024AY 2015-16

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No.635/Hyd/2022 & Sa No.49/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2015-16) Shri Sarat Gopal Boppana Vs. Asstt. C. I. T. Hyderabad Central Circle 2(3) Pan:Afcpb8083K Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 19/06/2024 घोषणा की तारीख/Pronouncement: 07/08/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao CAFor Respondent: : Shri Shakeer Ahmed, DR
Section 131Section 132Section 139(1)Section 143(3)Section 153ASection 271(1)(c)Section 274

called upon the assessee to explain as to why the penalty cannot be levied u/s 271(1)(c) r.w. Explanation 5A of section 271(1)(c) thereto. During the penalty proceedings the Assessing Officer observed that, during the PO operation at the residential premises of the assessee ... with the explanation furnished by the assessee and according to the Assessing Officer, the case of the assessee fall under Explanation 5A of section 271(1)(C) of the Act, where it has been clearly stated that notwithstanding that such income is declared by him in any return of income

Jaipur Gem Crafts, Jaipur vs. ITO, Ward-5(1), Jaipur

In the result, the appeal of the assessee is allowed with no orders as to costs

ITA 327/JPR/2024[2015-16]Status: DisposedITAT Jaipur07 Aug 2024AY 2015-16

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sanjay Godha, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 271(1)Section 271CSection 274

income of the assessee. 2.4 Consequently after passing the order of ld. CIT(A) in Quantum appeal, the AO imposed penalty under section 271 (1) (c ) of the Income Tax Act and on further appeal penalty order passed by AO was upheld. 2.5 Now at the very outset the imposition ... CRAFTS VS ITO, WARD 5 (1), JAIPUR versus Arrow traders Private Limited 322 ITR 316 the court has held that no penalty under section 271(1)( c) can be imposed where income is determined on estimate and similar view has also been taken by Hon’ble Punjab and Haryana High

Cidco Employees Co-Op. Credit Society Ltd, Navi Mumbai vs. Ward 28(1)(3), Navi Mumbai

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

ITA 700/MUM/2024[2020-21]Status: DisposedITAT Mumbai07 Aug 2024AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalcidco Employees Co-Op. Credit Society, Ground Floor, Cidco Bhavan, Cbd Belapur, Navi Mumbai – 400 614 Pan:Aaaac2203N ..... Appellant Vs. Ito Ward 28(1) (3)/ Nfac Delhi ..... Respondent

For Appellant: Shri Bhupendra Shah, Ld. ARFor Respondent: Shri H. M. Bhatt, Ld. DR
Section 143Section 234BSection 250Section 271(1)Section 80Section 80P

erred in charging interest u/s. 234B and 234C of the Act. 3. The Id. AO erred in initiating penalty proceedings under section 271(1) (c) of the Act. [B] General:- • The appellant reserve rights to add alter or delete any portion of this appeal before its conclusion. • This appeal

ADIT, Cirlce- 1(1), International Taxation, New Delhi vs. American Express Banking Corp. (India Branch), New Delhi

In the result, the Appeal filed by the Assessee in ITA No

ITA 6455/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 92C(3)Section 92F

234C and 234D of the Act. 20. The Learned AO has erred, in facts and in law, by initiating penalty proceedings under section 271(1)(c) of Act in relation to transfer pricing adjustment and without recording any adequate reasons for such initiation. The above grounds of appeal are mutually

American Express Banking Corp. (India Branch), New Delhi vs. ADIT, Cirlce- 1(1), International Taxation, New Delhi

In the result, the Appeal filed by the Assessee in ITA No

ITA 6253/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 92C(3)Section 92F

234C and 234D of the Act. 20. The Learned AO has erred, in facts and in law, by initiating penalty proceedings under section 271(1)(c) of Act in relation to transfer pricing adjustment and without recording any adequate reasons for such initiation. The above grounds of appeal are mutually

Shree Gunatit Jyot Mahila Trust, Anand vs. The ITO, Ward - Exemption, Vadodara

In the result, the appeal of the assessee is allowed

ITA 326/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad06 Aug 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 326/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2016-17) िनधा"रण वष" िनधा"रण वष" Shree Gunatit Jyot Ito बनाम बनाम/ बनाम बनाम Mahila Trust Ward, Exemption Vs. Post Box No.23, Pappaji Vadodara Marg, Vallabh Vidhyanagar, Anand, Gujarat, 388120 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaats8722P (Appellant) .. (Respondent) Shri S. N. Soparkar, Sr. Advocate & अपीलाथ" ओर से /Appellant By : Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr Date Of Hearing 31/07/2024 Date Of Pronouncement 06/08/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’) Dated 12.01.2024 For The Assessment Year 2016-17. 2. The Brief Facts Of The Case Are That The Assessee Is A Charitable Trust Registered Under The Bombay Public Trust Act And

For Appellant: Shri Parin Shah, A.RFor Respondent: Smt. Mamta Singh, Sr. DR
Section 11(1)Section 11(1)(d)Section 12ASection 271(1)(c)

total income of the trust and the assessed income was computed at Rs. Nil. The AO had, however, initiated penalty proceeding under Section 271(1)(c) of the Act in respect of wrong claim of deduction under Section 11(1) of the Act in respect of building construction amount ... Rs.2,36,23,637/-. A separate penalty order under Section 271(1)(c) of the Act dated 30.03.2019 was passed by the AO, after allowing an opportunity to the assessee and penalty of Rs.78,31,400/- was imposed @ 100% of tax sought to be evaded for furnishing inaccurate particulars

Assistant Commissioner of Income Tax, Central Circle-2(1), Nagpur vs. Faiz Zakir Vali, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 231/NAG/2022[2010-11]Status: DisposedITAT Nagpur06 Aug 2024AY 2010-11

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Smt. Veen AgrawalFor Respondent: Shri Kailash C. Kanojiya
Section 271(1)(c)

sole issue raised in this appeal is, whether or not the the learned CIT(A) were justified in deleting the penalty under section 271(1)(c) of the Income Tax Act, 1961 ("the Act") for ` 1,04,13,300. 3. Having heard both the parties, we find that the sole

Harshal Suresh Karvir, Palghar vs. National Faceless Assessment Centre, Delhi

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

ITA 4477/MUM/2023[2013-14]Status: DisposedITAT Mumbai06 Aug 2024AY 2013-14

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm Harshal Suresh Karvir National Faceless Assessment Centre 2Nd Floor, E Ramp, Jawaharlal Nehru 397, Sutar Ali, Chinchani, Vs. Palghar, Palghar-401 503 Stadium, Delhi

For Appellant: Shri Tanmay PhadkeFor Respondent: Shri P. D. Chogule
Section 144Section 147Section 250Section 271(1)(c)Section 274Section 69

well as the ld. CIT(A) is not precise on which limb the penalty has been levied as per section 271(1)(c) of the Act, i.e., whether for ‘concealment of particulars of income’ or for ‘furnishing inaccurate particulars of income’. It is the settled proposition of law that ... upon in Manjunath Cotton & Ginning Factory (supra)) wherein it is observed that concealment of income and furnishing of inaccurate particulars of income in Section 271(1)(c) of the Act, carry different meanings/connotations. Therefore, the satisfaction of the Assessing Officer with regard to only one of the two breaches mentioned

Income Tax Officer, Delhi vs. Ac Infrastructure, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1038/DEL/2024[2015-16]Status: DisposedITAT Delhi06 Aug 2024AY 2015-16

Bench: Shri Saktijit Dey & Shri S Rifaur Rahmanassessment Year : 2015-16 Income Tax Officer, Vs. M/S Ac Infrastructure, 3Rd Floor, Bhanot Corner, Delhi Room No. 380A, 3Rd Pampos Enclave, Floor, C.R. Building, Greater Kailash, I.P. Estate, New Delhi - 48 New Delhi – 110 002 (Pan: Aafca7166B) (Appellant) (Respondent) Appellant By : Shri M.P. Rastogi, Adv. Respondent By : Shri Kanv Bali, Sr. Dr. Date Of Hearing : 01.08.2024 Date Of Pronouncement : 06.08.2024 Order

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri Kanv Bali, Sr. DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)

read with Rule 8D was required to be made. Appreciating the aforesaid factual position, Ld. First Appellate Authority deleted the penalty imposed under section 271(1)(c) of the Act. 4. We have considered rival submissions and perused the materials on record. The fact that the assessee had not earned

Gurvinder Singh Duggal, New Delhi vs. DCIT Central Circle-8, New Delhi

Appeals of the assessee stand allowed

ITA 2577/DEL/2023[2016-17]Status: DisposedITAT Delhi06 Aug 2024AY 2016-17

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

Section 132Section 153ASection 154Section 250Section 271(1)(C)Section 271(1)(c)

levied concealment penalties of Rs.41,51,717/- and Rs.51,01,899/-vide orders dated 23.03.2023 passed under section 271(1)(c) of the Act in AYs 2012-13 and 2016-17 respectively. Aggrieved, the appellant/assessee filed appeals, against the penalty orders, before the ITA No. 2576-2577/Del/2023 Gurvinder Singh ... records. We find force in the argument of the Ld. Counsel that when the quantum additions are deleted the concealment penalties levied under section 271(1)(c) of the Act for the said quantum cannot survive. Therefore, in view of the above, we hereby cancel the penalties of both years

Gurvinder Singh Duggal, New Delhi vs. DCIT Central Circle-8, New Delhi

Appeals of the assessee stand allowed

ITA 2576/DEL/2023[2012-13]Status: DisposedITAT Delhi06 Aug 2024AY 2012-13

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

Section 132Section 153ASection 154Section 250Section 271(1)(C)Section 271(1)(c)

levied concealment penalties of Rs.41,51,717/- and Rs.51,01,899/-vide orders dated 23.03.2023 passed under section 271(1)(c) of the Act in AYs 2012-13 and 2016-17 respectively. Aggrieved, the appellant/assessee filed appeals, against the penalty orders, before the ITA No. 2576-2577/Del/2023 Gurvinder Singh ... records. We find force in the argument of the Ld. Counsel that when the quantum additions are deleted the concealment penalties levied under section 271(1)(c) of the Act for the said quantum cannot survive. Therefore, in view of the above, we hereby cancel the penalties of both years

Nova Promoters and Finlease Pvt. Ltd., Delhi vs. ITO, New Delhi

ITA 3173/DEL/2014[2000-01]Status: DisposedITAT Delhi06 Aug 2024AY 2000-01

Bench: Shri S.Rifaur Rahman & Ms.Madhumita Roynova Promoters & Vs. Ito, Ward 13(3) Finlease Pvt. Ltd. Ito Building, I.P. Estate 7, Kapil Vihar, Pitampura, Delhi – 34

For Appellant: NoneFor Respondent: Shri Anshul
Section 147Section 271(1)(c)Section 68

instant appeal filed by the assessee is directed against the order dated 28.02.2014 passed by the CIT(A)-XVI Delhi, under Section 271(1)(c) of the Income Tax Act (hereinafter referred to as ‘the Act’) arising out of the order dated 22.08.2012 passed by the ITO, Ward ... Finally on the basis of the High Court order whereby and whereunder the addition made by the AO has been confirmed, penalty under Section 271(1)(c) of the Act to the tune of Rs.46,85,932/- has been imposed upon the assessee. 7. Before

Turimella Vasu Babu, Adoni vs. Income Tax Officer, Ward-1, Adoni

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 644/HYD/2024[2015-2016]Status: DisposedITAT Hyderabad05 Aug 2024AY 2015-2016

Bench: Shri K. Narasimha Charyआ.अपी.सं / Ita No. 643/Hyd/2024 & 644/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2015-16)

For Appellant: Adv.Manjula, appeared for Adv.Shaik Jeelani BashaFor Respondent: Shri Gudimella V P Pavan Kumar, DR
Section 271(1)(c)

/Hyd/ 2024 is in respect of the quantum addition whereas ITA No. 644 /Hyd/ 2024 is in respect of the penalty levied under section 271(1)(c) of the Income Tax Act, 1961 (for short “the Act”). 2 I.T.A.Nos.643 & 644/Hyd/2024, A.Y.2015-16 Turimella Vasu Babu 2. At the outset ... condoned. I have perused the order of the learned CIT(A) in the appeal of the assessee against levy of penalty under section 271(1)(c) of the Act. Learned CIT(A) dismissed this appeal for non-prosecution by the assessee by applying the ratio in the case

Turimella Vasu Babu, Adoni vs. Income Tax Officer, Ward-1, Adoni

In the result, appeals of the assessee are treated as allowed for statistical purposes

ITA 643/HYD/2024[2015-2016]Status: DisposedITAT Hyderabad05 Aug 2024AY 2015-2016

Bench: Shri K. Narasimha Charyआ.अपी.सं / Ita No. 643/Hyd/2024 & 644/Hyd/2024 (निर्धारण वर्ा / Assessment Year: 2015-16)

For Appellant: Adv.Manjula, appeared for Adv.Shaik Jeelani BashaFor Respondent: Shri Gudimella V P Pavan Kumar, DR
Section 271(1)(c)

/Hyd/ 2024 is in respect of the quantum addition whereas ITA No. 644 /Hyd/ 2024 is in respect of the penalty levied under section 271(1)(c) of the Income Tax Act, 1961 (for short “the Act”). 2 I.T.A.Nos.643 & 644/Hyd/2024, A.Y.2015-16 Turimella Vasu Babu 2. At the outset ... condoned. I have perused the order of the learned CIT(A) in the appeal of the assessee against levy of penalty under section 271(1)(c) of the Act. Learned CIT(A) dismissed this appeal for non-prosecution by the assessee by applying the ratio in the case

Dy. Commissioner of Income Tax, Circle-2(2), Hyderabad vs. Hsbc Electronic Data Processing India Private Limited, Hyderabad

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

ITA 1632/HYD/2017[2010-11]Status: DisposedITAT Hyderabad05 Aug 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri Rajan Vora, C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 10ASection 115Section 115JSection 251(1)(a)Section 37(1)Section 41(1)

excess refund issued amounting to Rs. 39,11,505. - Initiating penalty proceedings 8. Initiation of penalty proceedings under section 271(1) (c) of the Act. Additional Grounds: Deduction in respect of education cess and secondary and higher secondary education cess paid under section 37(1 ... hence the same is not required to be separately adjudicated. Further Ground No.8 of the assessee relates to initiation of penalty proceedings under section 271(1) (c) of the Act. This ground is held to be raised prematurely and hence not adjudicated separately. 6. Ground No.1 of the assessee relates

Kailash Parashar, Pushkar, Ajmer vs. Income Tax Officer Ward 1(3), Ajmer

In the result, the appeal of the assessee is allowed

ITA 90/JPR/2024[2016-17]Status: DisposedITAT Jaipur02 Aug 2024AY 2016-17

Bench: SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 2(14)Section 271(1)Section 271(1)(c)Section 54

opportunity of being heard. The final conclusion on the point as to whether the requirements of clauses (a), (b) and (c) of Section 271(1) have been satisfied would be reached only after the assessee has been heard or has been given a reasonable opportunity of being heard." 67. 'Concealment ... other cannot be sustained in law. It is needless to point out satisfaction of the existence of the grounds mentioned in Section 271(1)(c) when it is a sine qua non for initiation or proceedings, the penalty proceedings should be confined only to those grounds and the said grounds

Beekau Bhardwaj, New Delhi vs. Income Tax Officer, Jaipur

25. In view of the above discussion and findings, this appeal

ITA 524/JPR/2024[2012-13]Status: DisposedITAT Jaipur01 Aug 2024AY 2012-13

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

For Appellant: Shri Yogesh Sharma, AdvFor Respondent: Shri Anoop Singh (Addl. CIT)
Section 148Section 271(1)Section 271(1)(b)Section 271(1)(c)Section 271FSection 69A

assessment pertaining to quantum whereas in the remaining 3 appeals, there is challenge to three separate penalities levied under different sub-clauses of section 271(1) and Section 271F of the Act. 2. This appeal has been filed challenging order dated 07.03.2024. Vide impugned order Learned CIT(A) has partly ... that he had sufficient reason for non compliance with the said notices issued by the Assessing Officer. Having regard to the provisions of section 271(1)(b) and that the assessee failed to comply with notices issued even under section 142(1) of the Act, no ground for any leniency

Beekau Bhardwaj, New Delhi vs. Income Tax Officer, Jaipur

25. In view of the above discussion and findings, this appeal

ITA 523/JPR/2024[2012-13]Status: DisposedITAT Jaipur01 Aug 2024AY 2012-13

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

For Appellant: Shri Yogesh Sharma, AdvFor Respondent: Shri Anoop Singh (Addl. CIT)
Section 148Section 271(1)Section 271(1)(b)Section 271(1)(c)Section 271FSection 69A

assessment pertaining to quantum whereas in the remaining 3 appeals, there is challenge to three separate penalities levied under different sub-clauses of section 271(1) and Section 271F of the Act. 2. This appeal has been filed challenging order dated 07.03.2024. Vide impugned order Learned CIT(A) has partly ... that he had sufficient reason for non compliance with the said notices issued by the Assessing Officer. Having regard to the provisions of section 271(1)(b) and that the assessee failed to comply with notices issued even under section 142(1) of the Act, no ground for any leniency