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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)

Ranjeet Kumar (Individual), Begusarai vs. Income Tax Officer, Ward- 2 (1), Begusarai

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

ITA 198/PAT/2025[2015-16]Status: DisposedITAT Patna06 Aug 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271FSection 282Section 69

order of the Ld. A.O wherein the Ld. AO erred in initiating penalty proceedings u/s 271(1)(c) as the provisions of section 271(1)(c) of the Act are not attracted. 14. For that the Ld. CIT(A) has erred in upholding the order of the Ld. A.O wherein

Christudanam Yassaya, Thiruvananthapuram vs. ITO, Ward 1(1), Thiruvananthapuram

In the result, all four appeals are allowed

ITA 149/COCH/2025[2015-16]Status: DisposedITAT Cochin06 Aug 2025AY 2015-16

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 144Section 148Section 264Section 271(1)(c)Section 274Section 275(1)(c)

assessee against separate orders passed by the learned CIT(A), all dated 18.04.2024 / 01.03.2024, respectively confirming the imposition of penalty under Section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the respective assessment years. Since the issues involved in all these appeals ... assessment under Section 144 r.w.s. 264 was passed on 29.11.2019, determining the total income at Rs. 15,73,016. Simultaneously, penalty proceedings under Section 271(1)(c) were initiated, and notice under Section 274 r.w.s. 271(1)(c) was issued on 29.11.2019. The assessee filed a written reply. However

Christudanam Yassaya, Thiruvananthapuram vs. ITO, Ward 1(1), Thiruvananthapuram

In the result, all four appeals are allowed

ITA 148/COCH/2025[2014-15]Status: DisposedITAT Cochin06 Aug 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 144Section 148Section 264Section 271(1)(c)Section 274Section 275(1)(c)

assessee against separate orders passed by the learned CIT(A), all dated 18.04.2024 / 01.03.2024, respectively confirming the imposition of penalty under Section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the respective assessment years. Since the issues involved in all these appeals ... assessment under Section 144 r.w.s. 264 was passed on 29.11.2019, determining the total income at Rs. 15,73,016. Simultaneously, penalty proceedings under Section 271(1)(c) were initiated, and notice under Section 274 r.w.s. 271(1)(c) was issued on 29.11.2019. The assessee filed a written reply. However

Christudanam Yassaya, Thiruvananthapuram vs. ITO, Ward 1(1), Thiruvananthapuram

In the result, all four appeals are allowed

ITA 147/COCH/2025[2013-14]Status: DisposedITAT Cochin06 Aug 2025AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 144Section 148Section 264Section 271(1)(c)Section 274Section 275(1)(c)

assessee against separate orders passed by the learned CIT(A), all dated 18.04.2024 / 01.03.2024, respectively confirming the imposition of penalty under Section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the respective assessment years. Since the issues involved in all these appeals ... assessment under Section 144 r.w.s. 264 was passed on 29.11.2019, determining the total income at Rs. 15,73,016. Simultaneously, penalty proceedings under Section 271(1)(c) were initiated, and notice under Section 274 r.w.s. 271(1)(c) was issued on 29.11.2019. The assessee filed a written reply. However

Christudanam Yassaya, Thiruvananthapuram vs. ITO, Ward 1(1), Thiruvananthapuram

In the result, all four appeals are allowed

ITA 146/COCH/2025[2012-13]Status: DisposedITAT Cochin06 Aug 2025AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 144Section 148Section 264Section 271(1)(c)Section 274Section 275(1)(c)

assessee against separate orders passed by the learned CIT(A), all dated 18.04.2024 / 01.03.2024, respectively confirming the imposition of penalty under Section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the respective assessment years. Since the issues involved in all these appeals ... assessment under Section 144 r.w.s. 264 was passed on 29.11.2019, determining the total income at Rs. 15,73,016. Simultaneously, penalty proceedings under Section 271(1)(c) were initiated, and notice under Section 274 r.w.s. 271(1)(c) was issued on 29.11.2019. The assessee filed a written reply. However

Mata Deen, Kotkasim vs. Income Tax Officer, Jaipur

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

ITA 608/JPR/2025[2012-13]Status: DisposedITAT Jaipur06 Aug 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA No.608/JPR/2025 निर्धारणवर्ष / AssessmentYear : 2012-13 Shri Mata Deen Mohalla Jatwara, KOTKASIM ALWAR 301 702 (Raj) बनाम Vs. The ITO Ward 6(1) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AWNPD 0463 H अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri S.K. Gogra, CA राजस्व की ओरसे /Revenue by: Shri Gaurav Awasthi, JCIT-DR सुनवाई की तारीख / Date of Hearing उदघोषणा

For Appellant: Shri S.K. Gogra, CAFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 133(6)Section 148

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,’’SMC” JAIPUR Mk0 ,l- lhrky{eh

M/S Rajasthan State Industrial Development and Investment Corporation Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, both the appeals of the assessee are allowed as indicated hereinabove

ITA 310/JPR/2025[2014-15]Status: DisposedITAT Jaipur06 Aug 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274Section 80

11AM and show cause why an order imposing a penalty on you should not be made under section 271(1)© of the Income Tax Act, 1961. If no one attends this office on the said date of hearing, the case shall be decided on the basis of the material available ... merits. The Ld. CIT(A), however, without deciding the legal ground of assessee, confirmed the levy of penalty by applying Explanation 1 to section 271(1)(c) by holding that the amount of Rs.2,13,17,575/- added or disallowed by the AO which has reached finality in computing

M/S Rajasthan State Industrial Development & Investment Corporation Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, both the appeals of the assessee are allowed as indicated

ITA 309/JPR/2025[2013-14]Status: DisposedITAT Jaipur06 Aug 2025AY 2013-14
For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143(3)Section 14ASection 271(1)Section 271(1)(c)Section 274Section 80

11AM and show cause why an order imposing a penalty on you should not be made under section 271(1) of the Income Tax Act, 1961. If no one attends this office on the said date of hearing, the case shall be decided on the basis of the material available ... merits. The Ld. CIT(A), however, without deciding the legal ground of assessee, confirmed the levy of penalty by applying Explanation 1 to section 271(1)(c) by holding that the amount of Rs.2,13,17,575/- added or disallowed by the AO which has reached finality in computing

Rahul Springs Private Limited, Panagarh vs. DCIT, Circle -1, Durgapur

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

ITA 2426/KOL/2024[2014-2015]Status: DisposedITAT Kolkata06 Aug 2025AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)Section 271(1)(c)Section 68

आयकर अपीलीय अधिकरण कोलकाता 'ए' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘A’ BENCH, KOLKATA श्री संजय

Bioagile Therapeutics Private Limited, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 376/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2018-19

For Appellant: Smt. Pratibha R, Ld. Advocate
Section 143(3)Section 250Section 270ASection 270A(3)Section 80Section 80I

claim was not accepted or was not acceptable to the Revenue, that by itself would not, in our opinion, attract the penalty under Section 271(1)(c). If we accept the contention of the Revenue then in case of every Return where the claim made is not accepted by Assessing ... Officer for any reason, the assessee will invite penalty under Section 271(1)(c). That is clearly not the intendment of the Legislature”. 8. The Hon’ble Apex Court in the case of Hindustan Steel Ltd Vs. State of Orissa on 4 August

ITO 41(3)(1), Mumbai vs. Deepika Anil Agarwal, Mumbai

In the result the appeal filed by the revenue stands

ITA 1885/MUM/2025[2011-12]Status: DisposedITAT Mumbai06 Aug 2025AY 2011-12

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawal

Section 10(38)Section 132Section 132(4)Section 143Section 147Section 148Section 263Section 68

test of human probabilities." " Ground 4 On the facts and circumstances of the case the AO erred in initiating penalty proceedings under section 271(1)(c) of Income Tax Act, 1961. The Ld. AO erred in initiating penalty under section 271(1)(C) of the Income Tax Act, 1961. HUMBLE

Mrs. Surekha L/R of Late Shri. Devaraj, Bangalore vs. Income Tax Officer, Ward-7(2)(5), Bangalore

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

ITA 910/BANG/2025[2015-16]Status: DisposedITAT Bangalore05 Aug 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2015-16

For Respondent: Shri B.S. Balachandran
Section 144Section 144BSection 147Section 148Section 148ASection 234ASection 269SSection 271(1)(c)Section 271D

erred in charging interest under section 234A and 234B of the Act. 13. The Ld AO erred in initiating penalty proceedings under section 271(1)(c) and 271F of the Act. Each of the above grounds is independent and without prejudice to the other grounds of appeal preferred

Mohd. Umar, Nuh, Mewat vs. Income Tax Officer, Ward 1(5), Faridabad

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

ITA 3078/DEL/2025[2011-12]Status: DisposedITAT Delhi05 Aug 2025AY 2011-12

Bench: Shri Vikas Awasthyआअसं.3078/िद"ी/2025 (िन.व. 2011-12) Mohd. Umar, Village Siroli, Tehsil Punhana, Mewat, ...... अपीलाथ"/Appellant Nuh, Palwal, Haryana 121103 Pan: Aabpu-9980-G बनाम Vs. Income Tax Officer, Ward-1(5) ..... "ितवादी/Respondent Cgo Complex, Faridabad, Haryana 121001 अपीलाथ" "ारा/Appellant By : None "ितवादी"ारा/Respondent By : Ms. Sudha Gupta, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 31/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 31/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)] Dated 03.02.2025, For Assessment Year 2011-12. 2. The Appeal Is Time Barred By 8 Days. The Assessee Has Filed A Petition For Condonation Of Delay Supported By An Affidavit & Medical Records. After Perusal Of Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, But Is For The Reasons Stated In The Condonation Petition Which Appears To Be Bonafide. Hence, Delay In Filing Of Appeal Is Condoned & Appeal Is Admitted For Hearing On Merits.

For Appellant: NoneFor Respondent: Ms. Sudha Gupta, Sr.DR
Section 143(3)Section 271(1)(c)

Samson Perinchery, 392 ITR 4 has held that penalty initiated on one limb and levied on the other limb of section 271(1)(c) of the Act is unsustainable. 6. In light of the fact that penalty has been initiated by the AO in a vague and ambiguous manner

Shri Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 338/CHANDI/2017[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

consider whether assessee deserves to be visited with penalty or not, we deem it appropriate to take note of the relevant provision i.e. Section 271(1)(c) of the Act. Section 271(1)(c) of the Act has a direct bearing on the controversy and, therefore, it is salutary upon ... take note of the relevant provisions of Section 271(1)(c) along with Explanation-1 which read as under: “271. Failure to furnish returns, comply with notices, concealment of income, etc. (1). If the Assessing Officer or the Commissioner (Appeals) or the CIT in the course of any proceedings under

Sh. Dinesh Sethi, Ludhiana vs. ITO, Ludhiana

The appeals are dismissed

ITA 376/CHANDI/2014[2006-07]Status: DisposedITAT Chandigarh04 Aug 2025AY 2006-07

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 376/Chd/2014 & "नधा"रण वष" / Assessment Year : 2006-07 Shri Janesh Sethi, Legal Heir Of बनाम The Ito, Late Shri Dinesh Sethi, Ward – 1(1), Vs Prop. M/S R.S. Trading Corp., Ludhiana. C-434, Urban Estate Focal Point, Ludhiana. "थायी लेखा सं./Pan /Tan No: Aaqpk1200Q अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr तार"ख/Date Of Hearing : 23.06.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 04.8.2025

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 131Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 69A

consider whether assessee deserves to be visited with penalty or not, we deem it appropriate to take note of the relevant provision i.e. Section 271(1)(c) of the Act. Section 271(1)(c) of the Act has a direct bearing on the controversy and, therefore, it is salutary upon ... take note of the relevant provisions of Section 271(1)(c) along with Explanation-1 which read as under: “271. Failure to furnish returns, comply with notices, concealment of income, etc. (1). If the Assessing Officer or the Commissioner (Appeals) or the CIT in the course of any proceedings under

DCIT Central Circle 7 (1) Mumbai, Mumbai vs. Panther Investrade Limited, Mumbai

In the result, both the Cross appeals no

ITA 416/MUM/2025[2003-04]Status: DisposedITAT Mumbai04 Aug 2025AY 2003-04

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Rajiv Khandelwal & Akash Kumar, ARsFor Respondent: Shri Virabhadra S. Mahajan (Sr. DR)
Section 271(1)(c)

case and in law, The learned CIT(A) has erred in deleting the penalty of Rs. 89,13,326/- imposed under Section 271(1)(c) of the Income Tax Act, 1961, despite the fact that the Assessee had deliberately diverted interest-bearing funds for non- business purposes for the entire ... ITAT in the AY 2001-02, and therefore, the penalty imposed by the AO for the AY 2002- 03 is fully justified under Section 271(1)(c) of the Act. 3. On the facts and in the circumstances of the case, the learned CIT(A) erred in deleting the penalty

DCIT(Central Circle)-7(1), Mumbai vs. Panther Investrade Limited, Mumbai

In the result, both the Cross appeals no

ITA 415/MUM/2025[2002-03]Status: DisposedITAT Mumbai04 Aug 2025AY 2002-03

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Rajiv Khandelwal & Akash Kumar, ARsFor Respondent: Shri Virabhadra S. Mahajan (Sr. DR)
Section 271(1)(c)

case and in law, The learned CIT(A) has erred in deleting the penalty of Rs. 89,13,326/- imposed under Section 271(1)(c) of the Income Tax Act, 1961, despite the fact that the Assessee had deliberately diverted interest-bearing funds for non- business purposes for the entire ... ITAT in the AY 2001-02, and therefore, the penalty imposed by the AO for the AY 2002- 03 is fully justified under Section 271(1)(c) of the Act. 3. On the facts and in the circumstances of the case, the learned CIT(A) erred in deleting the penalty

Radiant Gems, Mumbai vs. The Income Tax Officer Ward 34(3)(2), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 2075/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Aug 2025AY 2013-14

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 250Section 271(1)(c)

No.4203 & 4304/Mum/2024, Assessment Years 2012-13 & 2011-12, dated 03/10/2024] whereby, in identical facts and circumstances, the Tribunal had deleted penalty levied under Section 271(1)(c) of the Act on the ground that addition was made on estimate basis. In view of the above, we decline to interfere with ... order passed by the CIT(A) deleting the penalty levied under Section 271(1)(c) of the Act, and therefore, Ground No.1, 2 and 3 raised by the Revenue are dismissed.” 7.3 Respectfully following the finding of the Tribunal (supra), we uphold the finding of the Tribunal on the issue

Radiant Gems, Mumbai vs. The Income Tax Officer Ward 34(3)(2), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 2074/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Aug 2025AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 250Section 271(1)(c)

No.4203 & 4304/Mum/2024, Assessment Years 2012-13 & 2011-12, dated 03/10/2024] whereby, in identical facts and circumstances, the Tribunal had deleted penalty levied under Section 271(1)(c) of the Act on the ground that addition was made on estimate basis. In view of the above, we decline to interfere with ... order passed by the CIT(A) deleting the penalty levied under Section 271(1)(c) of the Act, and therefore, Ground No.1, 2 and 3 raised by the Revenue are dismissed.” 7.3 Respectfully following the finding of the Tribunal (supra), we uphold the finding of the Tribunal on the issue

Ogd Services Limited, Mumbai vs. DCIT, Circle 14(1)(1), Mumbai

In the result, the appeal is allowed

ITA 1407/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Aug 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Devendra Jain, ARFor Respondent: Mr. Virabhadra S. Mahajan,(Sr. DR)
Section 143(3)Section 271Section 271(1)(c)Section 274Section 43BSection 44A

Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as “CIT(A)"] pertaining to a penalty order passed u/s. Section 271(1)(c) of the Income-tax Act, 1961 [hereinafter referred to as “Act”] dated 31.12.2021for the Assessment Year [A.Y.] 2019-20. 2. The grounds ... that appellant has concealed any income or particular of income and passed a penalty order determining a penalty of Rs.16,97,141/-under section 271(1)(c). 2. On the facts and circumstances of the case, the penalty order passed by the learned AO under section 274 r.w.s Section 271