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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 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1653/CHNY/2025[2019-20]Status: DisposedITAT Chennai21 Oct 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

u/s.271(1)(c) of the Act. 13. It was also submitted by the assessee that the deeming provisions contained in Explanation 5A to section 271(1)(c) of the Act were not applicable to the facts of the present case. The assessee submitted that during the course of search proceedings ... year. 1-8-2 ITA Nos.1650 to 1655/Chny/2025 14. The assessee, relying upon various judicial pronouncements, contended that for invoking Explanation 5A to section 271(1)(c) of the Act, it is a condition precedent that incriminating material or documents must be unearthed during the course of search, and that

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1652/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

u/s.271(1)(c) of the Act. 13. It was also submitted by the assessee that the deeming provisions contained in Explanation 5A to section 271(1)(c) of the Act were not applicable to the facts of the present case. The assessee submitted that during the course of search proceedings ... year. 1-8-2 ITA Nos.1650 to 1655/Chny/2025 14. The assessee, relying upon various judicial pronouncements, contended that for invoking Explanation 5A to section 271(1)(c) of the Act, it is a condition precedent that incriminating material or documents must be unearthed during the course of search, and that

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1651/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Oct 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

u/s.271(1)(c) of the Act. 13. It was also submitted by the assessee that the deeming provisions contained in Explanation 5A to section 271(1)(c) of the Act were not applicable to the facts of the present case. The assessee submitted that during the course of search proceedings ... year. 1-8-2 ITA Nos.1650 to 1655/Chny/2025 14. The assessee, relying upon various judicial pronouncements, contended that for invoking Explanation 5A to section 271(1)(c) of the Act, it is a condition precedent that incriminating material or documents must be unearthed during the course of search, and that

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Chennai

In the result, all the six appeals of the Revenue are

ITA 1650/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Oct 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

u/s.271(1)(c) of the Act. 13. It was also submitted by the assessee that the deeming provisions contained in Explanation 5A to section 271(1)(c) of the Act were not applicable to the facts of the present case. The assessee submitted that during the course of search proceedings ... year. 1-8-2 ITA Nos.1650 to 1655/Chny/2025 14. The assessee, relying upon various judicial pronouncements, contended that for invoking Explanation 5A to section 271(1)(c) of the Act, it is a condition precedent that incriminating material or documents must be unearthed during the course of search, and that

Avani Dipakbhai Shah, Vadodara vs. The ACIT, Circle Intl. Txn., Vadodara

The appeal of the assessee is allowed

ITA 707/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jigar Adhyaru, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 132Section 153CSection 271F

filing was July 31, 1979. The delay of 32 months led the Assessing Officer to levy a penalty of ₹32,130 under section 271(1)(a) of the Income-tax Act, 1961, which was upheld by the Commissioner (Appeals). On further appeal, the Tribunal held that the assessee had reasonable

Avani Dipakbhai Shah, Vadodara vs. The ACIT, Circle Intl. Txn., Vadodara

The appeal of the assessee is allowed

ITA 706/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jigar Adhyaru, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 132Section 153CSection 271F

filing was July 31, 1979. The delay of 32 months led the Assessing Officer to levy a penalty of ₹32,130 under section 271(1)(a) of the Income-tax Act, 1961, which was upheld by the Commissioner (Appeals). On further appeal, the Tribunal held that the assessee had reasonable

Avani Dipakbhai Shah, Vadodara vs. The ACIT, Circle Intl. Txn., Vadodara

The appeal of the assessee is allowed

ITA 705/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Jigar Adhyaru, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 132Section 153CSection 271F

filing was July 31, 1979. The delay of 32 months led the Assessing Officer to levy a penalty of ₹32,130 under section 271(1)(a) of the Income-tax Act, 1961, which was upheld by the Commissioner (Appeals). On further appeal, the Tribunal held that the assessee had reasonable

Mikal Bhupendrabhai Patel, Petlad vs. I.T.O Ward 1(3)(1), Petlad

Accordingly, the appeal filed by the assessee is dismissed

ITA 474/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Jainish Parikh, CAFor Respondent: Shri Abhijit, Sr. DR
Section 139Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

income of the assessee. The total assessed income was thus determined at Rs. 53,15,500/- from undisclosed sources. Penalty proceedings under section 271(1)(c) were also initiated, and interest under sections 234A, 234B, 234C, and 234D was charged as applicable. 4. In appeal, the assessee filed the appeal ... decision of the ITAT, Delhi Special Bench in Motorola Inc. v. DCIT (96 TTJ 1). The ground challenging initiation of penalty proceedings under section 271(1)(c) was also dismissed as being consequential. The remaining grounds being general in nature were treated as dismissed. Accordingly, the CIT(A) dismissed

Mikal Bhupendrabhai Patel, Petlad vs. I.T.O Ward 1(3)(1), Petlad

Accordingly, the appeal filed by the assessee is dismissed

ITA 473/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Jainish Parikh, CAFor Respondent: Shri Abhijit, Sr. DR
Section 139Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

income of the assessee. The total assessed income was thus determined at Rs. 53,15,500/- from undisclosed sources. Penalty proceedings under section 271(1)(c) were also initiated, and interest under sections 234A, 234B, 234C, and 234D was charged as applicable. 4. In appeal, the assessee filed the appeal ... decision of the ITAT, Delhi Special Bench in Motorola Inc. v. DCIT (96 TTJ 1). The ground challenging initiation of penalty proceedings under section 271(1)(c) was also dismissed as being consequential. The remaining grounds being general in nature were treated as dismissed. Accordingly, the CIT(A) dismissed

Nidhiben Mrugeshkumar Shah, Anand vs. The ACIT, (OSD), Ward-5, Anand

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

ITA 1627/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2011-12

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1627/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2011-12) बनाम/ Nidhiben Mrugeshkumar Assistant Commissioner Shah Of Income Tax (Osd) Vs. 3, Laksh Gold Bunglows, Ward-5, Anand B/H. Dz Patel High School, 80 Feet Road, Vidyanagar Road, Anand – 388001, Gujarat "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aprpj4087Q (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Viranch Modi, Ar ""यथ" क" ओर से/Respondent By : Smt. Kakoli Uttam Ghosh, Sr. Dr Date Of Hearing 13/10/2025 17/10/2025 Date Of Pronouncement

For Appellant: Shri Viranch Modi, ARFor Respondent: Smt. Kakoli Uttam Ghosh, Sr. DR
Section 271(1)(c)

NFAC”), Delhi dated 18.06.2025 confirming the levy of penalty for concealing particulars of income / furnishing inaccurate particulars of income, levied under Section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2011-12. ITA No. 1627/Ahd/2025 [Nidhiben Mrugeshkumar

Deepak Kumar Gupta, Kanpur vs. ITO Ward 2(1), Moradabad

In the result, appeal of the Assessee is partly allowed as indicated above

ITA 4528/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2014-15 Deepak Kumar Gupta, Vs. Income Tax Officer, 7/115, Flat No. B-1, Sai Niwas, Ward 2(1), Arya Nagar, Kanpur - 208020 Moradabad ( U.P) Uttar Pradesh. Pin: 244 001 Pan :Acmpg1836E (Appellant) (Respondent)

Section 142(1)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 271FSection 69

vide order dated 29.03.2022 made addition of Rs.40,23,000/- as per section 69 of the Act and separate penalty proceedings under Section 271(1)(c) and 271F of the Act were initiated. 3. Against order dated 29.03.2022 of Ld. AO, the appellant/assessee preferred appeal before

DCIT, Central Circle-1, Jaipur vs. Royal Developers, Jaipur

In the result, the appeal of the Revenue is dismissed

ITA 448/JPR/2025[2015]Status: DisposedITAT Jaipur15 Oct 2025

Bench: Him.

For Appellant: Shri Tarun Mittal, C.A. &For Respondent: Mrs Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142(1)Section 143(2)Section 153A

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR डॉ. एस.सीतालक्ष्मी, न्यायिक

Bhupendrabhai Bhikhabhai Patel, Anand vs. The ITO, Ward-3, Anand

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

ITA 1005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S. N. Divatia & Shri Samir Vora, ARsFor Respondent: Shri Suresh Chand Meena, Sr. DR
Section 142(1)Section 147Section 148Section 50C

total income was thus assessed at Rs.29,09,710/-, including agricultural income of Rs.1,72,560/- for rate purposes, and penalty proceedings under Section 271(1)(c) were also initiated for concealment of income. 5. In appeal, the learned CIT(Appeals) observed that the assessee had filed Form

Cognizance Constructions Private Limited, Hyderabad vs. ITO., Ward-1(1), Hyderabad

In the result, appeal of the Assessee is allowed for

ITA 344/HYD/2025[2013-14]Status: DisposedITAT Hyderabad15 Oct 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.344/Hyd/2025 निर्धारण वर्ष/Assessment Year 2013-2014 | M/S. Cognizance | Constructions Private | Limited, Hyderabad. | Pin – 500 075. Telangana. | Pan Aadcc1366M | (Appellant) Vs. The Income Tax Officer, Ward-1(1), Hyderabad. Telangana. (Respondent) निर्धारिती द्वारा/Assessee By: Ca Srinivas Maddury राजस्व द्वारा / Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख /Date Of Hearing: 13.10.2025 घोषणा की तारीख /Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 17.12.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The

For Appellant: CA Srinivas MadduryFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 139Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271ASection 271F

234B respectively. 11. The Ld.AO/NFAC erred in law and on facts of the case by initiation of penalty proceedings under Section 271A, Section 271(1)(c), section 271(1)(b) and section 271F of the Act. 12. Any other ground that may be urged at the time of hearing

Samir N Shah, Mumbai vs. Income Tax Officer, Circle 19(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 4393/MUM/2025[2012-13]Status: DisposedITAT Mumbai15 Oct 2025AY 2012-13

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarsamir N. Shah, A/35, Jeevan Villa Chs Narayan, Dabholkar Road, Nepean Road, Malabar Hill, Mumbai - 400006 ............... Appellant Pan: Aazps9084M V/S Income Tax Officer – 19(3), Piramal Chamber, Lower Parel, ……………… Respondent Mumbai - 400012

For Appellant: Shri V.P. Kothari, CAFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 143(3)Section 250Section 271Section 271(1)(c)

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 2012-13. 2 The present appeal is delayed by 250 days. Alongwith the appeal ... present appeal on the merits. 4. The only grievance of the assessee, in the present appeal, is against the levy of penalty under section 271(1)(c) of the Act. 5. We have considered the submissions of both sides and perused the material available on record. The brief facts

Opelina Finance and Investment Ltd., Delhi vs. ITO, Ward- 19(2), New Delhi

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

ITA 1423/DEL/2018[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2014-15] M/S. Opelina Finance & Vs Ito, Investment Ltd., 28, Nazafgarh Ward-19(2), Room Road, Delhi-110015. No.217, C.R.Building, Pan-Aaaco5195R New Delhi-110002. Appellant Respondent Appellant By Shri Salil Kapoor, Ms. Soumya Singh, Ms. Ananya Kapoor, Shri Utkarsh Kumar Gupta, Advocates Respondent By Ms. Harpreet Kaur Hansra, Sr.Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 15.10.2025 Order

Section 143(3)Section 14ASection 234ASection 250Section 271(1)(c)

view of facts and circumstances of the case the Assessing officer have erred in law and on facts in initiating penalty under section 271(1)(c). 13. That the interest charged u/s 234A and 234B is illegal, bad in law without jurisdiction. The said interest is wrongly charged

Income Tax Officer Ward 4(2)(3) Ahmedabad, Ahmedabad vs. Nitinbhai Kanubhai Patel, Ahmedabad

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

ITA 183/AHD/2025[2016-17]Status: FixedITAT Ahmedabad14 Oct 2025AY 2016-17

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : 2016-2017 Ito, Ward-4(2)(3) Shri Nitinbhai Kanubhai Patel Ahmedabad. Vs. Room No.303, 3Rd Floor Aaykar Bhavan Vejalpur, Ahmedabad. Pan : Aaspp 5802 F (Applicant) (Responent) : None Assessee By : Shri Veerabadram Vislavath, Sr.Dr. Revenue By सुनवाई क" तारीख/Date Of Hearing : 13/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 14/10/2025

For Appellant: Shri Veerabadram Vislavath, sr.DR
Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 54BSection 54B(1)(i)

claim for deduction under section 54B of Rs.2,95,92,616/-, and assessed total income at Rs.3,09,00,950/-. Penalty proceedings under section 271(1)(c) were initiated separately for furnishing inaccurate particulars of income. 2.8 Aggrieved, the assessee preferred appeal before the learned CIT(A). Before the learned

Kavita Balraj Lanjile, Pashan vs. ITO, Pune

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

ITA 1758/PUN/2025[2014-2015]Status: DisposedITAT Pune14 Oct 2025AY 2014-2015

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1758/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Kavita Balraj Lanjile, Vs. Ito, Ward-11(2), Pune. Flat No.401, Bldg. No.A-2, Shivranjan Tower, Someshwarwadi, Pune- 411008. Pan : Aaqpl5138C Appellant Respondent Assessee By : Shri Bharat Shah Revenue By : Shri Harshit Bari Date Of Hearing : 21.08.2025 Date Of Pronouncement : 14.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.01.2024 Passed U/S 271(1)(C) Of The It Act By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual Having Income From Profession & Business Income In The Shape Of Interest On Capital & Remuneration From Partnership Firm & Also Agricultural Income. The Assessee Furnished Her Return Of Income On 17.07.2014 Disclosing Professional Income, Income From Other

For Appellant: Shri Bharat ShahFor Respondent: Shri Harshit Bari
Section 139(5)Section 143(2)Section 143(3)Section 271(1)(c)Section 274Section 44A

Answers: Question No.1: If the assessment order clearly records satisfaction for imposing penalty on one or the other, or both grounds mentioned in Section 271 (1) (c), does a mere defect in the notice-not striking off the irrelevant matter-vitiate the penalty proceedings? 181. It does. The primary burden ... opinion, prima facie or otherwise, to launch penalty proceedings against the assessee. But that translates into action only through the statutory notice under section 271(1)(c), read with section 274 of IT Act. True, the assessment proceedings form the basis for the penalty proceedings, but they are not composite

Aruneswar Mukhopadhyay, Kolkata vs. ACIT, Circle 1(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1057/KOL/2025[2015-2016]Status: DisposedITAT Kolkata14 Oct 2025AY 2015-2016

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1057/Kol/2025 Assessment Year: 2015-2016 Aruneswar Mukhopadhyay,……………….……Appellant 64, Rajni Mukherjee Road, Sahapur, Kolkata-700038, West Bengal [Pan:Adspm1879J] -Vs.- Assistant Commissioner Of Income Tax,…..Respondent Circle-1(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Rajesh Kumar Mishra, Advocate, Appeared On Behalf Of The Assessee Shri Mrinmay Basak, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 25, 2025 Date Of Pronouncing The Order: October 14, 2025 O R D E R

Section 154Section 271(1)(c)Section 56(2)

Assessing Officer, as order under section 154 dated 08.02.2024 was passed to allow the assessee credit of tax. Penalty proceeding under section 271(1)(c) and 271F was initiated for concealment of income and non-filing of ITR of the Income Tax Act, 1961. 5. On being aggrieved, the assessee

Ganges Tieup Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2570/KOL/2024[2012-2013]Status: DisposedITAT Kolkata14 Oct 2025AY 2012-2013

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am Ganges Tieup Pvt. Ltd. Ito Ward 9(1), 127, 1St Floor, P-7, Chowringhee Square, Netaji Subhash Road, Kolkata-700069, Vs. Kolkata-700001, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaecg6645G Assessee By : S/Shri Soumitra Choudhury & Pranabesh Sarkar, Ars Revenue By : Shri Sanat Kumar Raha, Dr Date Of Hearing: 27.08.2025 Date Of Pronouncement: 14.10.2025

For Appellant: S/Shri Soumitra Choudhury &For Respondent: Shri Sanat Kumar Raha, DR
Section 120Section 127Section 143(2)Section 143(3)

petition is allowed. Consequential proceedings are also set aside and quashed. Accordingly, the notice dated 6th January, 2010 regarding the penalty proceedings under section 271(1)(c) for the assessment year 2006-07 is also set aside and quashed. The application being G. A. No. 81 of 2010 is also