“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)

Swiss Re Global Business Solutions India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bangalore

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

ITA 397/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Jan 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 133(6)

under section 234B of the Income Tax Act, 1961; 20. Learned AO has erred in law and facts, in initiating penalty proceedings under section 271(1)(c) of the Act. The Appellant submits that each of above grounds is independent and without prejudice to one another. The Appellant craves leave

S.G Asia Holding (I) P. Ltd, Mumbai vs. Asst CIT Cir 4(2), Mumbai

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

ITA 4901/MUM/2012[2005-06]Status: DisposedITAT Mumbai20 Jan 2022AY 2005-06

Bench: Shri Promod Kumar ()And Ms. Suchitra Kamble () Assessment Year: 2005-06 M/S S.G. Asia Holdings (India) Pvt. Ltd., Acit, Cir-4(2), One Indiabulls Centre, 1102, 11Th Floor, Mumbai B-Wing, Tower 2, 841, Jupiter Mills, Vs. Senapatibapat Marg, Lower Parel, Mumbai-400013. Pan No. Aaecs 2909 R Appellant Respondent Assessee By : Mr. Niraj Sheth, Ar Revenue By : Mr.Ajit Kumar, Dr Date Of Hearing : 13/01/2022 Date Of Pronouncement : 20/01/2022

For Appellant: Mr. Niraj Sheth, ARFor Respondent: Mr.Ajit Kumar, DR

Section 143(3)Section 271Section 271(1)(c)Section 274Section 92C

confirming the 2 M/s S.G. Asia Holdings (India) Pvt. Ltd. penalty of Rs. 10,605,51 1 imposed by the AssessingOfficer (*AO") under section 271 (1)c) of the Income Tax Act, 1961 (‘Act'). 2. On the facts and in the circumstances of the case ... decisions of the quantum in the fresh proceedings after following the directions of the Hon’ble Supreme Court. Thus, the penalty under Section 271(1)(c) is quashed at this juncture. The appeal of the assessee is allowed. 8. In the result, the appeal filed by the assessee is allowed

DCIT-9(3)(2), Mumbai vs. M/S.Future E-Commerce Infrastructure Limited, Mumbai

ITA 4490/MUM/2018[2013-14]Status: DisposedITAT Mumbai19 Jan 2022AY 2013-14

Bench: Shri Kuldip Singh & Shri Prashant Maharishi, Assessment Year: 2013-14

For Appellant: Shri Vipul Joshi, A.RFor Respondent: Shri Pinisetty Satya Prasanth, D.R

Section 143(3)Section 271(1)(c)Section 274Section 27iSection 40

passed by Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] deleting the penalty levied by the Assessing Officer under section 271(1)(c) of the Act on the grounds inter alia that:- 2 M/s. Future E-Commerce Infrastructure Ltd. “1. On the facts ... period expenses respectively, Assessing Officer initiated the penalty proceedings against the assessee by way of issuance of notice under section 274 read with section 271(1)(c) of the Act. Declining the contentions raised by the assessee the Assessing Officer proceeded to levy the penalty to the tune of Rs.1

Cisco Systems Services B.V, Bangalore vs. Deputy Commissioner of Income Tax International Taxation Circle-1(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 961/BANG/2017[2012-13]Status: DisposedITAT Bangalore19 Jan 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 961/Bang/2017 Assessment Year : 2012-13 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, International Taxation, Mahatma Gandhi Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca : Dr. Manjunath Karkaihalli, Revenue By Cit Dr Date Of Hearing : 19-01-2022 Date Of Pronouncement : 19-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 27.02.2017 Passed U/S. 143(3) R.W.S. 144C(14) Of The Income- Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. - India Branch (Hereinafter Referred To As The 'Appellant.) Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Deputy Commissioner Of Income-Tax (International Taxation) - Circle 1(1) ('Assessing Officer' Or 'Ao') Dated February 27, 2017 In Pursuance Of The Directions & The Revised Directions Issued By The Dispute Resolution Panel ('Drp'), Bangalore Dated December 29, 2016 & January 16. 2017 Respectively, Under Section 253 Of The Income-Tax Act, 1961 ('Act) On The Following Grounds:

For Appellant: Shri Rajan Vora, CA

Section 143(3)Section 253Section 92C

learned AO has erred in issuing the notice of demand under section 156 of the Act and notice initiating penalty proceeding under section 271(1)(c) along with draft assessment order and thereby making the same as final order and thus, not following the provisions of section 144C

Shorline Hotel P. Ltd., Mumbai vs. Dy CIT- CC-1(2), Mumbai

In the result, all these appeals by the assessee stand partly allowed

ITA 253/MUM/2021[2009-10]Status: DisposedITAT Mumbai18 Jan 2022AY 2009-10

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Section 271(1)(c)Section 80P(2)(a)Section 80P(4)

Shri Shamim Yahya (AM) :- These are appeals by the assessee against respective orders of learned Commissioner of Income Tax (Appeals), wherein penalty under section 271(1)(c) of the I.T.Act has been confirmed. 2. Since the issues are common and connected and the appeals were heard together, these are consolidated ... made 100% disallowance for bogus purchases without doubting the sales. Upon assessee’s appeal Ld.CIT(A) has granted a part relief. Penalty under section 271(1)(c) of the I.T.Act was also levied, which was confirmed by Ld.CIT(A). Assessee has also raised a ground before ld.CIT(A) that

Choice Diamond, Mumbai vs. ACIT 19 (1), Mumbai

In the result, the impugned order is quashed and appeal of the assessee is allowed

ITA 27/MUM/2020[2012-13]Status: DisposedITAT Mumbai18 Jan 2022AY 2012-13

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantआअसं. 27/मुं/2020 ("न. व. 2012-13) Choice Diamond, Cc-4101, Bharat Diamond Bourse, Bandra Kurla Complex, Bandra (East), Mumbai 400 051 Pan: Aaafc-0677-R ...... अपीलाथ" /Appellant बनाम Vs. Asstt. Commissioner Of Income Tax- 19(1), 203, Matru Mandir, Tardeo, ..... ""तवाद"/Respondent Mumbai- 400 007 अपीलाथ" "वारा/ Appellant By : Ms. Dharshti Shah ""तवाद" "वारा/Respondent By : Shri R.A. Dhyani सुनवाई क" "त"थ/ Date Of Hearing : 18/01/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 18/01/2022 आदेश/ Order

For Appellant: Ms. Dharshti ShahFor Respondent: Shri R.A. Dhyani

Section 143(3)Section 271(1)(c)Section 274

Income Tax(Appeals) -29, Mumbai [ in short ‘the CIT(A)’] dated 13/12/2019 for the assessment year 2012-13, confirming levy of penalty under section 271(1)(c) of the Income Tax Act, 1961( in short ‘the Act’). 2 2. Ms. Dharshti Shah appearing on behalf of the assessee raised ... Assessing Officer is defective as the same has been issued in pre-printed performa without striking off the irrelevant limb of section 271(1)(c) of the Act. The ld.Authorized Representative for the assessee pointed that a perusal of assessment order dated 30/01/2014 passed under section

M/S Eskay Knits (India) Ltd., Mumbai vs. DCIT CC 5 (3), Mumbai

ITA 135/MUM/2020[2008-09]Status: DisposedITAT Mumbai18 Jan 2022AY 2008-09

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: NoneFor Respondent: Shri Anil Das, D.R

Section 143(3)Section 147Section 271(1)(c)Section 274Section 7

confirmed by the CIT(A) on the grounds taken from A.Y. 2008-09 inter alia that; “1. That, the notice issued under section 271(1)(c) read with section 274 of the Act and the order passed under section 271(1)(c) of the Act are illegal ... circumstances of the Appellant’s case and in law, has erred in upholding the levy of penalty of Rs.7,00,77,680 under section 271(1)(c) of Income Tax Act, 1961 (the "Act") for furnishing inaccurate particulars of income with regard to disallowance of depreciation of Rs.12

ITO -32(2)(1), Mumbai vs. M/S. Liberal Realtors Limited Liability Partnership, Mumbai

In the result, appeal of the Revenue for A

ITA 450/MUM/2021[2015-16]Status: DisposedITAT Mumbai17 Jan 2022AY 2015-16

Section 10(38)Section 143(3)Section 68Section 69C

Tribunal is also incompetent. In the case of Banta Singh Kartar Singh (supra), a similar question arose in an order under Section 271(1)(c) of the Act. The Division Bench of the High Court of Punjab & Haryana, placing reliance on the decision of the Mumbai High Court in JivatlalPurtapshi

Landmark Education India, Mumb Ai vs. ITO (Exemption)-1(4), Mumbai

ITA 563/MUM/2021[2008-09]Status: DisposedITAT Mumbai14 Jan 2022AY 2008-09

Bench: Shri Shamim Yahya & Shri Kuldip Singhassessment Year: 2008-09

For Appellant: Shri Nitesh Joshi, A.RFor Respondent: Shri Shailja Rai, D.R

Section 143(3)Section 250Section 271(1)(c)Section 274

passed by Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] deleting the penalty levied by the Assessing Officer under section 271(1)(c) of the Act on the grounds inter alia that: “1. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre ... erred in not cancelling penalty levied 2 M/s. Landmark Education India under section 271(1)(c) of the Income Tax Act, 1961 ('the Act') on the appellant. 2. The CIT(A) erred in disposing the appeal (being appeal against levy of penalty under section 271(1

Shoreline Hotel Ltd., Mumbai vs. Dy CIT CC-1(2), Mumbai

In the result, appeal is allowed

ITA 258/MUM/2021[2014-15]Status: DisposedITAT Mumbai13 Jan 2022AY 2014-15

For Appellant: Mr.Anuj Kisnadwala. ARFor Respondent: Mr.Vivek Upadhay. DR

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 145(3)Section 271(1)(c)

assessee. It is a fact on record that based on addition sustained by learned Commissioner (Appeals), the AO has imposed penalty under section 271(1)(c) of the Act. 6. While recording satisfaction for initiating penalty proceedings in the assessment order, the AO has observed that the assessee had furnished ... inaccurate particulars of income and thereby concealed the income. Whereas, in the order passed imposing penalty under section 271(1)(c) of the Act, the AO has alleged furnishing of inaccurate particulars of income. On a perusal of the show cause notice dated 25.03.2015 issued under section 274 r.w.s. 271

Olympus Medical Systems India Pvt. Ltd., Gurugram vs. ACIT, Circle- 3(1), Gurugram

In the result, appeal of the assessee in ITA No

ITA 873/DEL/2021[2016-17]Status: HeardITAT Delhi13 Jan 2022AY 2016-17

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Mahesh Shah, CIT-DR

Section 143(3)Section 144B

that the Appellant has furnished inaccurate particulars of income in respect of each item of disallowance/ additions and in initiating penalty proceedings under section 271(1)(c) of the Act. The Appellant craves leave to add, alter, modify or delete such other objections before or during the course of hearing

M/S. Cisco Systems Services B.V. India Branch, Bengaluru vs. Deputy Commissioner of Income Tax, International Taxation, Circle- 1(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 2572/BANG/2019[2011-12]Status: DisposedITAT Bangalore12 Jan 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(It)A No. 2572/Bang/2019 Assessment Year : 2011-12 M/S. Cisco Systems Services B.V. – India The Deputy Branch, Commissioner Of Brigade South Parade, Income Tax, No. 10, Mahatma Gandhi International Taxation, Road, Circle – 1(1), Vs. Bangalore – 560 001. Bangalore. Pan: Aaccc4836D Appellant Respondent Assessee By : Shri Rajan Vora, Ca Revenue By : Shri Pradeep Kumar, Cit (Dr) Date Of Hearing : 04-01-2022 Date Of Pronouncement : 12-01-2022 Order Per Beena Pillaithis Appeal By Assessee Is Directed Against The Order Of The Ld.Ao Dated 31.12.2015 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 [The Act] On The Following Grounds: “Based On The Facts & Circumstances Of The Case & In Law, Cisco Systems Services B.V. —India Branch (Hereinafter Referred To As 'The Appellant'), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Learned Assessing Officer (Hereinafter Referred To As The 'Learned Ao') Dated October 15, 2019 Under Section 147 Read With Section 143(3) Read With Section 144C Of The Income-Tax Act, 1961 (`The Act') Pursuant To The Directions Dated September 23, 2019 Issued By The Drp U/S 144C(5) Of The Act ('The Impugned Order') Inter-Alia On The Following Grounds:

For Appellant: Shri Rajan Vora, CAFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 147Section 156Section 234BSection 271(1)(c)Section 92C(2)

draft assessment order 4. Erred in issuing the notice of demand under section 156 of the Act and notice initiating penalty proceeding under section 271(1)(c) along with draft assessment order and thereby making the same as final order and thus, not following the provisions of section 144C

Sri Amit Kumar Loya, Gulbarga vs. The Deputy Commissioner of Income Tax Central Circle, Belagavi

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

ITA 38/BANG/2019[2011-12]Status: DisposedITAT Bangalore11 Jan 2022AY 2011-12

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2011-12

For Appellant: Smt. Prathibha, A.RFor Respondent: Sri M.K. Biju, D.R

Section 132Section 143(3)Section 148Section 153CSection 271(1)(c)Section 50C

Section 271 of the Act specifies imposition of penalty for failure to furnish returns, comply with the notices, concealment of income, etc. Section 271(1)(c) of the Act authorises the assessing authority or the Commissioner of Income-tax (Appeals) to levy penalty in case of concealment of particulars ... income or for furnishing inaccurate particulars of income. Explanation 1 appended to Section 271(1)(c) of the Act specifies as to when the assessee fails to offer an explanation or the explanation so offered is found to be false or the explanation is not proved and when the explanation

Smt. Ravinder Kaur Bhatia, Mumbai vs. ITO Ward 19 (3)(2), Mumbai

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

ITA 7003/MUM/2019[2007-08]Status: DisposedITAT Mumbai10 Jan 2022AY 2007-08

Bench: Ms. Suchitra Raghunath Kamble () & Shri Amarjit Singh () Assessment Year: 2007-08 Smt. Ravinder Kaur Bhatia, Income Tax Officer, Ward 308, Tulsiani Chamber, Nariman Point, Vs. 19(3)(2), Mumbai-400021. Mumbai-400020. Pan No. Agapb 8595 M Appellant Respondent

For Appellant: Mr. Hariom Tulsian, ARFor Respondent: Ms. Neha Thakur, DR

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

ignoring the contention of the appellant that the appeal was filed against the order Smt. Ravinder Kaur Bhatia 2 passed under section 271(1)(c) of the I.T. Act, 1961 and not against the order passed under section 271F of the I.T. Act, 1961. 3. On the facts and circumstances ... both on facts and in law, in ignoring the contention of the appellant that the appeal was filed against the order passed under section 271(1)(c) of the I.T. Act, 1961 and not against the order passed under section 271F of the I.T. Act, 1961. 3. On the facts

Aggressive Digital Systems Private Limited, Haryana vs. ITO, Ward-1(1), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 874/DEL/2021[2016-17]Status: DisposedITAT Delhi10 Jan 2022AY 2016-17

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 874/Del/2021 : Asstt. Year : 2016-17 Aggressive Digital Systems Pvt. Ltd., Vs Income Tax Officer, Plot No. 596-597, Sector-8, Imt Ward-1(1), Manesar, Gurgaon, Haryana-122050 Gurgaon (Appellant) (Respondent) Pan No. Aanca7751J Assessee By : Mr. Siddhartha Sinha, Adv. Revenue By : Sh. Anand Kumar Kedia, Cit Dr Date Of Hearing: 06.01.2022 Date Of Pronouncement: 10.01.2022

For Appellant: Mr. Siddhartha Sinha, AdvFor Respondent: Sh. Anand Kumar Kedia, CIT DR

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

shown as INR 70,52,530. 2. The Ld. AO has erred in law, facts and circumstances by initiating the penalty proceedings under section 271(1)(c) of the Act against the appellant for concealment of particulars of income. 2 Aggressive Digital Systems Pvt. Ltd. 3. That on the facts

Aesthetica Enterprises Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5133/DEL/2017[2010-11]Status: HeardITAT Delhi07 Jan 2022AY 2010-11

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri P.C. Yadav, AdvFor Respondent: Shri Mukesh Jha, Sr.DR

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

Income Tax (Appeals)-XXIV, New Delhi [for short “CIT(A)”] dated 29.06.2017 arising from the order passed by the Assessing Officer under Section 271(1)(c) of the Income Tax Act, 1961 (for short “Act”) concerning Assessment Years 2009-10, 2010-11. Since the issues involved in all these cases ... grounds of appeal in ITA No.5133/Del/2017, the assessee seeks to challenge imposition of penalty of Rs.3,58,595/- levied under Section 271(1)(c). 4. When the matter was called for hearing, the learned counsel for the assessee at the outset referred to the petition filed under Rule

Aesthetica Enterprises Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 6, New Delhi

In the result, the appeal of the assessee is allowed

ITA 5132/DEL/2017[2009-10]Status: HeardITAT Delhi07 Jan 2022AY 2009-10

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri P.C. Yadav, AdvFor Respondent: Shri Mukesh Jha, Sr.DR

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

DCIT, Gulbarga vs. M/S Jupiterbioscience Ltd., Bidar

In the result, appeal by the revenue is partly allowed

ITA 628/BANG/2009[2004-05]Status: DisposedITAT Bangalore06 Jan 2022AY 2004-05

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

For Appellant: NoneFor Respondent: Shri. Sumeer Kumar Singh, CIT(DR)(ITAT), Bengaluru

Section 271(1)Section 35(1)(iv)Section 35(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENTAND SHRI B. R. BASKARAN, ACCOUNTANT

Delfab Global Pvt. Ltd., Gurgaon vs. ITO, Ward- 1(4), Gurgaon

In the result, the appeal of the Assessee is dismissed

ITA 6256/DEL/2017[2012-13]Status: DisposedITAT Delhi06 Jan 2022AY 2012-13

Bench: Shri R. K. Panda & Shri N. K. Choudhry

Section 143(3)Section 271Section 271(1)(a)Section 271(1)(c)Section 32

Revenue. Therefore, there was no intention of the Assessee to conceal income or furnish inaccurate particulars of income within the meaning of Section 271(1)(c) of the Income Tax Act, 1961 to evade taxes.” 4.1. The above reply given by the Assessee was found not satisfactory, consequently ... passed an order under Section 271(1)(a) of the Act on 21/09/2015 by imposing the penalty of Rs. 1,73,813/- which is 100% of tax being evaded. 5. Aggrieved by the said order of penalty dated 21/9/2015, the Assessee has preferred an appeal before CIT(A), who after

DCIT, Gulbarga vs. M/S Jupiter Bioscience Ltd., Bidar

In the result, appeal by the revenue is partly allowed

ITA 951/BANG/2009[2006-07]Status: DisposedITAT Bangalore05 Jan 2022AY 2006-07

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

For Appellant: NoneFor Respondent: Shri. Sumeer Kumar Singh, CIT(DR)(ITAT), Bengaluru

Section 271(1)Section 35(1)(iv)Section 35(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENTAND SHRI B. R. BASKARAN, ACCOUNTANT