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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)

Smt Rashmi Ramesh Damani, Mumbai vs. DCIT, Circle 17(1), Mumbai

ITA 1129/MUM/2025[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri M. P. LohiaFor Respondent: Shri Vikas Chandra
Section 143(3)Section 271(1)(c)

matters remained unattended. Therefore, the appeal before the Tribunal could not filed within the prescribed time. On receipt of Penalty Order passed under Section 271(1)(c) of the Act, she contacted tax professional who advised her to file appeal before the Tribunal. In the aforesaid facts and circumstances

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

proceedings On the facts and in the circumstances of the case and in law, the learned DCIT erred in initiating penalty proceedings under section 271(1)(c) of the IT Act.” 4. Ground No.1 is general in nature, and therefore, the same needs no specific adjudication. 5. Grounds No.2 ... Therefore, the same need no separate adjudication. 57. Ground No.16 raised in assessee's appeal pertains to the initiation of penalty proceedings under section 271(1)(c) of the Act, which is premature in nature. Therefore, the said ground is dismissed. 58. In the result, the appeal by the assessee

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

proceedings On the facts and in the circumstances of the case and in law, the learned DCIT erred in initiating penalty proceedings under section 271(1)(c) of the IT Act.” Ground No.1 is general in nature, and therefore, the same needs no specific adjudication. 5. Grounds No.2 ... Therefore, the same need no separate adjudication. 57. Ground No.16 raised in assessee’s appeal pertains to the initiation of penalty proceedings under section 271(1)(c) of the Act, which is premature in nature. Therefore, the said ground is dismissed. 58. Inthe result, the appeal by the assessee

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

proceedings On the facts and in the circumstances of the case and in law, the learned DCIT erred in initiating penalty proceedings under section 271(1)(c) of the IT Act.” Ground No.1 is general in nature, and therefore, the same needs no specific adjudication. 5. Grounds No.2 ... Therefore, the same need no separate adjudication. 57. Ground No.16 raised in assessee's appeal pertains to the initiation of penalty proceedings under section 271(1)(c) of the Act, which is premature in nature. Therefore, the said ground is dismissed. 58. In the result, the appeal by the assessee

Thermo Fisher Scienftific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

proceedings On the facts and in the circumstances of the case and in law, the learned DCIT erred in initiating penalty proceedings under section 271(1)(c) of the IT Act.” Ground No.1 is general in nature, and therefore, the same needs no specific adjudication. 5. Grounds No.2 ... Therefore, the same need no separate adjudication. 57. Ground No.16 raised in assessee’s appeal pertains to the initiation of penalty proceedings under section 271(1)(c) of the Act, which is premature in nature. Therefore, the said ground is dismissed. 58. Inthe result, the appeal by the assessee

Neetu Gupta, Punjab vs. The Income Tax Officer, Ward-1, Kapurthala, Punjab

In the result, the appeal is allowed for statistical purpose

ITA 4496/DEL/2025[2011-12]Status: DisposedITAT Delhi02 Jan 2026AY 2011-12
Section 250Section 271(1)(c)

ITA No.4496/Del/2025 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH "B"NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON'BLE VICE

Raees Alam Siddiqui, Ghazipur vs. Dy. C.I.T., Range - 1, Varanasi

In the result, the appeal of the assessee is allowed

ITA 39/VNS/2024[2015-2016]Status: DisposedITAT Varanasi31 Dec 2025AY 2015-2016

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Arvind Shukla, AdvocateFor Respondent: Smt. Amandeep Kaur, Sr. DR
Section 143(3)Section 145(3)Section 271Section 271(1)(c)

CHOUDHARY, A.M.: This is an appeal filed by the assessee against the orders of the ld. CIT(A), NFAC confirming the penalty under section 271(1)(c) that was levied upon the assessee vide the orders of the ld. Assessing Officer dated 25.01.2022. The grounds of appeal are as under ... Appeals), NFAC has erred both in law and on facts in confirming penalty Rs.2,13,250/ levied of by assessing officer under section 271(1)(c) of Income Tax Act, 1961. 2. Because the learned Commissioner of Income Tax (Appeals), NFAC has erred both in law and on facts

Amar Diwakar, Kanpur Nagar vs. Dy. Commissioner of Income Tax, Circle-4, Kanpur

The appeal of the assessee stands allowed for statistical purposes

ITA 117/LKW/2025[2012-13]Status: DisposedITAT Lucknow31 Dec 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Amar Diwakar V. Dcit J0512, Avas Vikas Circle 4 Keshavpuram, Kalyanpur Kanpur Kanpur Nagar (U.P) Tan/Pan:Aiypd7324G (Applicant) (Respondent) Applicant By: Shri Pradeep Seth, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 20.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That As Per Information Gathered By The Department From Network Management System (Nms) Portal, The Assessee Had Earned Salary Income Of Rs.17,50,162/- From Fiit Jee Ltd & Had Made Cash Deposit Of Rs.11,50,000/- In His Saving Bank Account During The Year Under Consideration. The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Assessing Officer (Ao) Initiated Proceedings Under Section 147 Of The Income Tax Act, 1961 After Issuing Notice Under Section 148 Of The Act To The Assessee. In Response To The Notice Under Section 148 Of The Act

For Respondent: Shri R.R.N. Shukla, D.R
Section 133(6)Section 147Section 148Section 250Section 271(1)(c)Section 69A

148/144 of the Act, computing the total income of the assessee at Rs.33,77,540/-. 2.4 The AO also initiated penalty proceedings under section 271(1)(c) of the Act, separately. 2.5 Aggrieved, the Assessee preferred an appeal before the NFAC, which set aside the order

Dy Commissioner of Income Tax, Mumbai vs. Bp India Pvt Ltd, Mumbai

In the result, the grounds of appeal raised by Revenue are

ITA 4873/MUM/2025[2012-13]Status: DisposedITAT Mumbai31 Dec 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2012-13 (Physical Hearing) Dy. Commissioner Of Income Tax, Bp India Pvt. Ltd. Room No.535, Aayakar Bhavan, Pb No. 19411, Technopolis Vs. Mumbai – 400020. Knowledge Park, Andheri, Mumbai- 400043. Pan No. – Aaccb2020Q (Appellant) (Respondent) C.O. No. 277/M/2025 In Ita No.4873/M/2025 Assessment Year: 2012-13

For Appellant: Ms. Chandni Shah/ Mr. AmolFor Respondent: Shri Bhagirath Ramawat (SR. D.R.)
Section 234DSection 271(1)(c)

facts and in the circumstances of the case and in law, the Ld. AO erred in proposing to initiate penalty proceedings under section 271(1)(c) of the Act. The Assessee prays that the Ld. AO be directed to drop the penalty proceedings under section 271(1

Pallavi Kamal Shah, Mumbai vs. Income Tax Officer, Income Tax Department

In the result, appeal of the assessee is dismissed

ITA 6317/MUM/2024[2013-2014]Status: DisposedITAT Mumbai31 Dec 2025AY 2013-2014

Bench: Shri Pawan Singh& Smt. Renu Jauhri(Physical Hearing) Pallavi Kamal Shah Ito, Ward-30(1)(1), Mumbai A-601, Bhimsen Chs Ltd., Marve Vs Maharashtra-400051. Road, Malad West, Maharashtra - 400064. [Pan: Avops7447Q] Appellant / Assessee Respondent / Revenue

Section 124Section 142Section 143(2)Section 144Section 144BSection 144B(1)(xiv)Section 144B(1)(xvi)Section 147Section 148Section 254(1)

crore on account of unexplained share trading and added under section 69A. The assessing officer initiated penalty under section 271F, penalty under section 271(1)(c) for concealment of income as well as penalty under section 271(1)(b) for non- compliance of various notices. 3. Aggrieved by the additions

Lifestyle and Media Holdings Limited, Delhi vs. Dy. Commissioner of Income Tax, Circle 18(1), New Delhi

In the result, this appeal of the assessee is allowed

ITA 3714/DEL/2024[2015-16]Status: DisposedITAT Delhi31 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Section 143(3)Section 2(13)Section 71

income. Grounds of appeal Nos. 1 and 2 are dismissed. 4.2 Ground of appeal No. 3 challenges the initiation of penalty proceedings under section 271(1)(c). The said ground also states that the appellant craves leave to alter, amend or withdraw all or any of the grounds of appeal

Lifestyle and Media Holding Ltd, New Delhi vs. ACIT, Circle-18(1), New Delhi

In the result, this appeal of the assessee is allowed

ITA 255/DEL/2020[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Section 143(3)Section 2(13)Section 71

income. Grounds of appeal Nos. 1 and 2 are dismissed. 4.2 Ground of appeal No. 3 challenges the initiation of penalty proceedings under section 271(1)(c). The said ground also states that the appellant craves leave to alter, amend or withdraw all or any of the grounds of appeal

Lifestyle and Media Holding Ltd, New Delhi vs. DCIT, Circle-18(1), New Delhi

In the result, this appeal of the assessee is allowed

ITA 64/DEL/2019[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Section 143(3)Section 2(13)Section 71

income. Grounds of appeal Nos. 1 and 2 are dismissed. 4.2 Ground of appeal No. 3 challenges the initiation of penalty proceedings under section 271(1)(c). The said ground also states that the appellant craves leave to alter, amend or withdraw all or any of the grounds of appeal

Rohan Promotors Pvt. Ltd., New Delhi vs. ITO Ward - 21(3), New Delhi

In the result, assessee’s appeal in ITA No

ITA 4849/DEL/2019[2007-08]Status: DisposedITAT Delhi31 Dec 2025AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

Section 142(1)Section 143(1)Section 147Section 148Section 271(1)(c)

finding in quantum appeal, remitting back the matter to the file of the Learned First Appellate Authority, the consequential penalty levied under Section 271(1)(c) of the Act, do not survive and is deleted accordingly. 5. In the result, assessee’s appeal in ITA No. 968/Del/2017 is allowed

M/S Rohan Promotors Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result, assessee’s appeal in ITA No

ITA 968/DEL/2017[2007-08]Status: DisposedITAT Delhi31 Dec 2025AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

Section 142(1)Section 143(1)Section 147Section 148Section 271(1)(c)

finding in quantum appeal, remitting back the matter to the file of the Learned First Appellate Authority, the consequential penalty levied under Section 271(1)(c) of the Act, do not survive and is deleted accordingly. 5. In the result, assessee’s appeal in ITA No. 968/Del/2017 is allowed

Ipf Vikram India Private Limited, Chandigarh vs. Dy. Commissioner of Income Tax, Circle, Panchkula

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

ITA 1204/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 Dec 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 143(3)Section 148

income was reassessed at Rs. 6,27,43,248/-, interest was charged under sections 234A, 234B, 234C, and 234D, and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 8. Against the order of the AO the assessee went in appeal before

Deputy Commisioner of Income Tax Central Circle 1(4) Ahmedabad, Ahmedabad vs. Falguni Suryakant Thakar, Ahmedabad

In the result, the appeal filed by the Revenue in quantum appeal in IT(SS)A No

ITA 1563/AHD/2025[2009-10]Status: DisposedITAT Ahmedabad30 Dec 2025AY 2009-10

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 139Section 142(1)Section 153ASection 153A(1)Section 153CSection 271(1)(c)Section 69

Income Tax Act 1961 (hereinafter referred as the Act) and appellate order dated 18-06- 2025 against the penalty order levied under section 271(1)(c) of the Act relating to the same Asst. Year 2009-10. The assessee has filed Cross Objection against quantum appeal ... 271(1)(c) of the act and levied penalty of Rs. 1,34,49,260/- vide penalty order dated 27-06-2022 under section 271(1)(c) of the Act. 3. Aggrieved against the order, assessee filed an appeal before Ld. CIT(A) challenging the jurisdiction of assessment relating

Jyoti Shroff, Kolkata vs. D.C.I.T., Circle - 29, Kolkata

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

ITA 2277/KOL/2025[2014-2015]Status: DisposedITAT Kolkata30 Dec 2025AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 271(1)Section 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

Shri Vipul Bansal, Mumbai vs. Income Tax Officer Ward 7(1)(2), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5628/MUM/2025[2010-11]Status: DisposedITAT Mumbai30 Dec 2025AY 2010-11

Bench: Shri Sandeep Singh Karhail & Shri Makarand Vasant Mahadeokar

Section 131Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 37(1)Section 69C

alleged fictitious profit and made an addition of Rs.2,66,633/- under section 69C of the Act as unexplained expenditure. Penalty proceedings under section 271(1)(c) were also initiated separately. 9. Aggrieved by the reassessment order, the assessee preferred an appeal before the CIT(A). The appeal was dismissed

Sanjay Bansal, Uttar Pradesh vs. ACIT Circle-2(2)(1), Ghaziabad, Uttar Pradesh

In the result appeal of the Assessee is dismissed

ITA 1619/DEL/2025[2016-17]Status: DisposedITAT Delhi30 Dec 2025AY 2016-17

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR
Section 271(1)(c)Section 48

claimed as cost of acquisition for want of supporting evidence. Consequently, the assessed income was determined at Rs.69,48,472/-. Penalty proceedings under section 271(1)(c) were initiated and interest under sections 234B, 234C and 234D was charged as per law. 4. Aggrieved by the asses sment order