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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)

Arun Dwivedi, Delhi vs. ACIT, Circle-9(2), Delhi

In the result, appeal of the assessee is allowed

ITA 6123/DEL/2024[2014-15]Status: DisposedITAT Delhi22 Aug 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.6123/Del/2024 िनधा"रणवष"/Assessment Year:2014-15 बनाम Arun Dwivedi, Acit, B-12, Vivekanand Puri, Vs. Circle-9(2), Lucknow, Uttar Pradesh. Delhi. Pan No.Aalpd4998F अपीलाथ" Appellant ""यथ"/Respondent

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

reason that the penalty proceedings were initiated and penalty was levied without assigning specific charge, the exact limb of section 271(1)(c) of the Act. In other words, it is submitted that the Ld. Counsel submits that the AO did not specify under which limb of section 271(1 ... supra) the Hon’ble jurisdictional High Court held as under:- “The respondent had challenged the upholding of the penalty imposed under section 271(1)(c) of the Act, which was accepted by the Income Tax Appellate Tribunal. It followed the decision of the Karnataka High Court in CIT Vs. Manjunatha

Mithlesh Kumar Tripathi, Delhi vs. ITO, Ward-24(4), Delhi

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

ITA 4955/DEL/2024[2012-13]Status: DisposedITAT Delhi22 Aug 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 143(3)Section 147Section 148Section 2(22)Section 2(22)(e)Section 271(1)(c)

transactions were reimbursements for legitimate business expenses and not loans or advances. 6. Penalty Proceedings: That the initiation of penalty proceedings under Section 271(1)(c) of the Income Tax Act, 1961, by the AO is without basis. There was no concealment of income or furnishing of inaccurate 2 Mithlesh

Sanjeev Kumar, Bulandshahr vs. ACIT, Central Circle- 14, New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 9328/DEL/2019[2013-14]Status: DisposedITAT Delhi22 Aug 2025AY 2013-14

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman, Accoutant Member A.Yr. : 2013-14 Sanjeev Kumar, Vs. Acit, Cc-14, New Delhi 77-78, Rama Royal Residency, Milk Mohsangarh, Siyana Road, Bulandshahr, Uttar Pradesh-203001 (Pan: Abbpk0132H) (Appellant) (Respondent)

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Ms. Amisha Gupt, CIT(DR)
Section 139Section 153ASection 271(1)(c)Section 271A

High Court in the case of PCIT vs. Neeraj Jindal (2017) 393 ITR 1 (Del. HC) wherein, it has been observed as under:- “Section 271(1)(c), read with section 153A of the Income Tax Act, 1961 – Penalty - for concealment of income (Revised return) – Assessment years ... revised return has been accepted by the AO, then merely by virtue of fact that such return showed a higher income, penalty under section 271(1)(c) cannot be automatically imposed-Held, yes- Whether once Assessing Officer accepts revised return filed under section 153A, original return under section 139 abates

Lahmeyer International Gmbh, Gurgaon vs. DDIT, New Delhi

In the result, appeals of assessee in ITA Nos

ITA 784/DEL/2014[2010-11]Status: DisposedITAT Delhi22 Aug 2025AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Satyam Sethi, AdvFor Respondent: Shri Vedanshu Tripathi, CIT- DR
Section 143(3)Section 144C(13)Section 234ASection 234BSection 234CSection 271(1)(c)

India- Germany Tax Treaty. 3. Levying interest under section 234A, section 234B and section 234C of the Act. 4 Initiating penalty proceedings under section 271(1)(c) of the Act for Assessment Year 2009-10, which is inappropriate. 5. Not granting credits for withholding taxes deducted by customers amounting ... customers amounting to Rs 33,44,095/-. At the time of computing the tax demand for the appellant. 4 Initiating penalty proceedings under section 271(1)(c) of the Act for Assessment Year 2009-10, which is inappropriate.” 19. For AY 2010-11, the facts being identical to the facts

M/S. Lahmeyer International Gmbh, Germany vs. DDIT, New Delhi

In the result, appeals of assessee in ITA Nos

ITA 5634/DEL/2012[2009-10]Status: DisposedITAT Delhi22 Aug 2025AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Naveen Chandra

For Appellant: Shri Satyam Sethi, AdvFor Respondent: Shri Vedanshu Tripathi, CIT- DR
Section 143(3)Section 144C(13)Section 234ASection 234BSection 234CSection 271(1)(c)

India- Germany Tax Treaty. 3. Levying interest under section 234A, section 234B and section 234C of the Act. 4 Initiating penalty proceedings under section 271(1)(c) of the Act for Assessment Year 2009-10, which is inappropriate. 5. Not granting credits for withholding taxes deducted by customers amounting ... customers amounting to Rs 33,44,095/-. At the time of computing the tax demand for the appellant. 4 Initiating penalty proceedings under section 271(1)(c) of the Act for Assessment Year 2009-10, which is inappropriate.” 19. For AY 2010-11, the facts being identical to the facts

Shri Ramchand Laxmandas Babani, Jaipur vs. Income Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 192/JPR/2025[2011-12]Status: DisposedITAT Jaipur21 Aug 2025AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ ITA No. 192/JPR/2025 निर्धारणवर्ष / AssessmentYear : 2011-12 Shri Ramchand Laxmandas Babani P.No.2, Shiv Shankar Colony Janta Colony, Jaipur – 302 004 (Raj) बनाम Vs. The ITO Ward -6(4) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ANYPB 6571 A अपीलार्थी / Appellant निर्धारिती की ओरसे/Assesseeby : Shri Mohit Balani, Advocate (Thru" V.C.) राजस्व की ओरसे /Revenue by: Shri Gautam Sin

For Appellant: Shri Mohit Balani, Advocate (Thru” V.C.)For Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 271(1)(c)

SHRI RAMCHAND LAXMANDAS BABANI VS ITO, WARD 6(4), JAIPUR stand of the Appellant that, the penalty of 22,60,090 levied under section 271(1)(c) is unjustified, as the disallowance of 1,53,549 towards cost of improvement was made solely due to the non-submission of supporting ... Patel V. Assistant Commissioner of Income-taxKS. JHAVERI AND KJ. THAKER, JJ TAX APPEAL NOS 1181, 1182 AND 1185 OF 20101DECEMBER 13, 20141 Section 271(1)(c) of the Income-tax Act, 1961-Penalty For concealment of income (Computation of Penalty) Assessment year 2002-03 Return of income filed

Harshadkumar Bhogilal Raval, Unjha, Dist. Mehsana, Gujarat vs. Income Tax Officer, Ward 1, Patan, Gujarat

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

ITA 489/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad21 Aug 2025AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2013-14

Section 142(1)Section 147Section 148Section 151Section 271(1)(b)

National Faceless Appeal Centre (NFAC) [hereinafter referred as ‘CIT(A)’] dated 09.01.2025 for the Assessment Year (A.Y.) 2013-14 in the proceedings under Section 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. The brief facts of the case are that the assessee ... total income of Rs.1,20,42,242/-. The Assessing Officer had also initiated penalty proceedings under Section 271(1)(b) of the Act for non-compliance to the notices u/s 142(1) of the Act. Thereafter, a separate penalty order u/s 271(1)(b) of the Act was passed

Ideal Energy Projects Limited, Nagpur vs. Central Circle 5(3), Mumbai

In the result, the appeal by the assessee is allowed

ITA 3343/MUM/2025[2012-2013]Status: DisposedITAT Mumbai21 Aug 2025AY 2012-2013

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailideal Energy Projects Limited., Plot No.1601, 5Th Floor, Gupta Tower, Science College Road, Civil Lines, Nagpur, Mumbai - 440001 ............... Appellant Pan : Aabci8643M V/S Deputy Commissioner Of Income Tax, Central Circle – 5(3), ……………… Respondent Room No.426, 4Th Floor, Kautilya Bhavan, C- Block, Bandra Kurla Complex, Bandra East, Mumbai Assessee By : Shri Hitesh P. Shah (Virtually Appear) Revenue By : Mr. Virabhadra S. Mahajan, Cit-Dr

For Appellant: Shri Hitesh P. Shah (Virtually appear)For Respondent: Mr. Virabhadra S. Mahajan, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 36(1)(iii)Section 57

learned Commissioner of Income Tax (Appeals)-53, Mumbai, [“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 2. The only grievance of the assessee is against the levy of penalty under section ... added the same to the total income of the assessee. 4. In the meanwhile, the penalty proceedings under section 271(1)(c) of the Act were initiated only on the addition made under section 57 of the Act, and vide order dated 21/03/2023 passed under section 271(1

Abhimanyu B Singh, Gurgaon vs. Income Tax Officer Ward (1), Gurgaon

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

ITA 1755/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Aug 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Naveen Chandraabhimanyu B Singh, Income Tax Officer, A-1001, Bestech Park View Ward-1(1), Spa Next, Sector-67, Vs. Gurugram. Gurgaon-122101. Pan-Afrpc2137A (Appellant) (Respondent) Assessee By Ca Mohd. Fesal Department By Shri Manish Gupta, Sr. Dr Date Of Hearing 14/08/2025 Date Of Pronouncement 21/08/2025 O R D E R Per Madhumita Roy, Jm: The Matter Relates To Confirmation Of Penalty Order Under Section 271(1)(C) Of The Income Tax Act, 1961 By The Ld. Commissioner Of Income Tax (Appeals), Delhi Dated 19.02.2025 For Assessment Year 2010-11. 2. At The Time Of Hearing Of The Instant Appeal, The Ld. Counsel For The Assessee Submits Before Us That The Quantum Appeal Has Been Set Aside To The File Of Ld. Cit(A) For Fresh Adjudication Of The Same By The Order Dated 30.06.20205 Passed By Co-Ordinate Bench In Ita No.1738/Del/2025 And, Therefore, Instant Issue Also Requires To Be Set Aside To The File Of The Ld. Cit(A) For Fresh Adjudication. Such Abhimanyu B Singh Vs. Ito Prayer Made By The Ld. Ar Has Not Been Objected By The Ld. Dr With All His Fairness. 3. Having Heard The Ld. Counsels Appearing For The Parties & Having Regard To The Facts & Circumstances Of The Case Particularly Quantum Appeal Having Been Disposed Off By Remitting The Issues To The File Of The Ld. Cit(A) For Fresh Adjudication By The Co-Ordinate Bench, This Appeal Is Disposed Off By Setting Aside The Issue To The File Of Ld. Cit(A) For Further Consideration. The Appeal Is Allowed For Statistical Purposes.

Section 271(1)(c)

14/08/2025 Date of Pronouncement 21/08/2025 O R D E R PER MADHUMITA ROY, JM: The matter relates to confirmation of penalty order under section 271(1)(c) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax (Appeals), Delhi dated 19.02.2025 for Assessment Year

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 532/COCH/2025[2020-21]Status: DisposedITAT Cochin20 Aug 2025AY 2020-21

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Pannivizha Service Cooperative Bank Ltd 891, M G Road, Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 531/COCH/2025[2018-19]Status: DisposedITAT Cochin20 Aug 2025AY 2018-19

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 530/COCH/2025[2014-15]Status: DisposedITAT Cochin20 Aug 2025AY 2014-15

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Pannivizha Service Cooperative Bank Ltd 891, M G Road, Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 529/COCH/2025[2013-14]Status: DisposedITAT Cochin20 Aug 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 528/COCH/2025[2012-13]Status: DisposedITAT Cochin20 Aug 2025AY 2012-13

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Pannivizha Service Cooperative Bank Ltd 891, Mg Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 527/COCH/2025[2011-12]Status: DisposedITAT Cochin20 Aug 2025AY 2011-12

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

hereinafter referred to as ‘the Act’]. Appeals pertaining to Assessment Years 2011-12 to 2014-15 challenge the levy of penalty under Section 271(1)(c) of the Act whereas the appeals pertaining to 2018-2019 & 2020-2021 challenge the levy of penalty under Section 270A of the Act. Since ... 30/06/2025, passed by the CIT(A) dismissing the appeal against the Penalty Order, dated 04/03/2025, whereby penalty of INR.48,515/- was levied under Section 271(1)(c) of the Act. 3. The grounds of appeal raised by the Assessee reads as under: “1. The appellant's accounts are subject

Vandana Anil Baladahre, Gondia vs. The Income Tax Officer, Panvel

In the result appeal of the assessee is allowed

ITA 1521/PUN/2025[2013-14]Status: DisposedITAT Pune20 Aug 2025AY 2013-14

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं / Ita No.1521/Pun/2025 धििाारण वर्ा / Assessment Year: 2013-2014 Vandana Anil Baladhare Vs Ito, Panvel Near Ramdeo Colony, Fulchur, Gondia-441601 Maharashtra Pan-Aqzpb8058L Appellant Respondent

For Appellant: NoneFor Respondent: Shri Shashank Ojha-
Section 142(1)Section 271(1)(b)Section 273B

notices issued u/s 142(1) of the Act dated 14.07.2021, 20.07.2021 & 02.08.2021. For this non compliance Ld. Assessing Officer (AO) invoked section 271(1)(b) of the Act and levied penalty of Rs.30,000/- @ Rs. 10,000/- for each non compliance. In the appeal filed before Ld. CIT(A) assessee

R V R Nagesh Legal Heir of Late Vengattarayalu Rajan, Kanchipuram vs. Income Tax Officer, Non Corp Ward - 22(4), Tambaram

ITA 789/CHNY/2025[2011-12]Status: DisposedITAT Chennai20 Aug 2025AY 2011-12

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.789/Chny/2025

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

legal grounds raised by the assessee. The Hon'ble Court, inter-alia, held that the impugned notice - 10 - ITA Nos.905 to 912/Chny/2020 under section 271(1)(c) did not specifically state as to whether assessee was guilty of concealing particulars of his income or had furnished inaccurate particulars of income ... transactions were through banking channels. Hence, the argument of Mrs.R.Hemalatha, learned Senior Standing Counsel appearing for the Revenue that both limbs of Section 271(1)(c) of the Act are attracted has to necessarily fall. Hence, we hold that there is inherent defect in the notice dated 30.3.2016 issued under

Naval Kishor Mundra, Mumbai vs. Income Tax Officer-4(2)(1), Mumbai

In the result, the appeal is accordingly allowed for

ITA 4200/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Aug 2025AY 2015-16

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 143(1)Section 143(3)Section 148Section 250Section 69

facts and circumstances of the case and law, 6 the Ld. CIT(A)erred in not quashing the penalty proceeding Rs.0 under section 271(1)(c) &271(1)(b) of Incometax Act, 1961 Ground 7. Appellant craves leave to add further grounds OR to amend or alter the existing grounds ... double taxation. 6. On the facts and circumstances of the case and law, the Ld. AO erred in invoking penalty provision under section 271(1)(c) & 271(1)(b) of Income tax Act, 1961. 7. Appellant craves leave to add further grounds or to amend or alter the existing grounds

Amar Singh vs. ITO Ward-2, Rewari

In the result, the appeal of the assessee is allowed

ITA 1229/DEL/2025[2013-14]Status: DisposedITAT Delhi20 Aug 2025AY 2013-14

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

Section 143(3)Section 148Section 271(1)Section 271(1)(c)

pertaining to A.Y. 2013-14 and arises out of the penalty order dated 20-03-2020 passed by the Assessing Officer under Section 271(1)(c) of the Income Tax Act, 1961 [hereinafter referred as ‘the Act’). 2. The assessee has raised the following grounds of appeal :- 1. That

Microad India Private Limited, Delhi vs. DCIT Circle - 16(2), Delhi

Appeals is allowed

ITA 4714/DEL/2024[2016-17]Status: DisposedITAT Delhi20 Aug 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Sh. Nikhil Khanna, CAFor Respondent: Sh. Vipul Kashyap, Sr. DR
Section 165Section 195Section 271(1)Section 271(1)(c)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘E’: NEW DELHI) BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI