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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)

Kalpana Dilip Mehta As Legal Heir of Dilip D Mehta, Mumbai vs. JCIT 19(2), Mumbai

In the result, the appeal of the Assessee is allowed

ITA 1387/MUM/2025[2007-08]Status: DisposedITAT Mumbai30 May 2025AY 2007-08

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2007-08

For Appellant: Shri Suchek Anchaliya, Ld. C.A. a/wFor Respondent: Shri Hemanshu Joshi, Ld. Sr. D.R
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69A

decision of the Hon’ble Supreme Court as under: 8. Therefore, it is obvious that it must be shown that the conditions under Section 271(1)(c) must exist before the penalty is imposed. There can be no dispute that everything would depend upon the Return filed because that ... terms "concealment of income" and "furnishing inaccurate particulars". The Court went on to hold therein that in order to attract the penalty under Section 271(1)(c), men- rea was necessary, as according to the Court, the word "inaccurate" signified a deliberate act or omission on behalf of the assessee

Sudhir Dayalal Mistry, Mumbai vs. ACIT Circle 20(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 5764/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 May 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 271(1)

liability. As such, the undisclosed sales of Rs. 54,39,879/-is added to the income of the assessee. Penalty proceedings under section 271(1) (c) of the I.T.Act, 1961 are initiated for concealing the income.” 4. Thereafter, he has made adhoc disallowance of 10% of the expenses debited

Ascot Realty Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Circle 1-, Thane

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

ITA 4644/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 May 2025AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Rishabh MarwahaFor Respondent: Shri. Ram Krishn Kedia (SR. DR.)
Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

well as notice issued under section 274 r.w.s. 271(1)(c) of the Act initiated the penalty under one limb of the section 271(1)(c) alleging 'Concealment of Income, HOWEVER, the penalty was levied on two other limbs l.e. for Furnishing Inaccurate particulars of Income'and for 'Deemed concealment ... under reporting of income. 23. On the above factual matrix of the case, the findings given in ITA No. 4644/Mum/2024 though was on section 271(1)(c) of the Act will apply mutatis mutandis to this appeal also, where the ld. AO initiated the penalty proceeding for misreporting of income

Ascot Realty Pvt. Ltd, Mumbai vs. Deputy Commissioner of Income Tax Circle -1, Thane

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

ITA 4643/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 May 2025AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Rishabh MarwahaFor Respondent: Shri. Ram Krishn Kedia (SR. DR.)
Section 143(1)Section 143(3)Section 250Section 271(1)(c)Section 274

well as notice issued under section 274 r.w.s. 271(1)(c) of the Act initiated the penalty under one limb of the section 271(1)(c) alleging 'Concealment of Income, HOWEVER, the penalty was levied on two other limbs l.e. for Furnishing Inaccurate particulars of Income'and for 'Deemed concealment ... under reporting of income. 23. On the above factual matrix of the case, the findings given in ITA No. 4644/Mum/2024 though was on section 271(1)(c) of the Act will apply mutatis mutandis to this appeal also, where the ld. AO initiated the penalty proceeding for misreporting of income

Uniphos Enterprises Ltd, Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 3878/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04
For Appellant: "I. TAXABILITY OF ADVANCE LICENCE BENEFIT RECEIVABLE: Rs.9,79
Section 254(1)Section 271(1)(c)Section 37(1)Section 80

Revenue's appeal is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section 80IB ... income was filed, and on which two views are possible. We endorse the view of Id CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

Asst CIT CC 38, Mumbai vs. Uniphos Enterprises Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 3534/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

appeal of the revenue is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section ... income was filed, and on which two views are possible. We endorse the view of ld CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

Addl CIT Cen RG IX, Mumbai vs. Uniphos Enterprises Ltd ( Formlery Known As United Phosphorus Ltd), Mumbai

In the result, the appeal of assessee is allowed

ITA 6236/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

appeal of the revenue is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section ... income was filed, and on which two views are possible. We endorse the view of ld CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

Uniphos Enterprises Ltd ( Formerly Known As United Phosphorus Ltd), Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 6224/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

appeal of the revenue is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section ... income was filed, and on which two views are possible. We endorse the view of ld CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

appeal of the revenue is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section ... income was filed, and on which two views are possible. We endorse the view of ld CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

appeal of the revenue is dismissed. ITA No. 3534/Mum/2014 by revenue for AY 2003-04 [in the matter of penalty levied under section 271(1)(c)]. 81. We find that the AO levied penalty under section 271(1)(c) on the issue reducing the profit eligible for deduction under section ... income was filed, and on which two views are possible. We endorse the view of ld CIT(A) that no penalty under section 271(1)(c) is leviable on the debatable issues. Moreover, we find that on all items we have allowed full relief to the assessee either

Geeta Chadha, Ludhiana vs. Deputy Commissioner of Income Tax, Centre Circle-1, Jalandhar

In the result, both the appeals of the assessees are allowed

ITA 51/ASR/2025[2014-15]Status: DisposedITAT Amritsar29 May 2025AY 2014-15

Bench: Sh. Udayan Das Gupta & Sh. Brajesh Kumar Singhi.T.A. No. 50/Asr/2025 Assessment Year: 2014-15 Sumesh Chadha, C/O Benepal Vs. Cit, C.C.-1, Service Station, Transport Jalandhar. Nagar, Ludhiana, Punjab. [Pan:-Abfpc1459B] (Respondent) (Appellant)

Section 142(1)Section 147Section 153CSection 250Section 271Section 271(1)Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. BRAJESH KUMAR

Sumesh Chadha, Ludhiana vs. Deputy Commissioner of Income Tax, Centre Circle-1, Jalandhar

In the result, both the appeals of the assessees are allowed

ITA 50/ASR/2025[2014-15]Status: DisposedITAT Amritsar29 May 2025AY 2014-15

Bench: Sh. Udayan Das Gupta & Sh. Brajesh Kumar Singhi.T.A. No. 50/Asr/2025 Assessment Year: 2014-15 Sumesh Chadha, C/O Benepal Vs. Cit, C.C.-1, Service Station, Transport Jalandhar. Nagar, Ludhiana, Punjab. [Pan:-Abfpc1459B] (Respondent) (Appellant)

Section 142(1)Section 147Section 153CSection 250Section 271Section 271(1)Section 271(1)(b)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. BRAJESH KUMAR

Usha Singh, Bareilly vs. Income Tax Officer Ward 2(3) Bareilly, Bareilly

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

ITA 379/LKW/2024[2016-2017]Status: HeardITAT Lucknow29 May 2025AY 2016-2017

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2016-17 Usha Singh V. The Income Tax Officer 201/7, Doctors Colony Ward 2(3) Civil Lines Bareilly Bareilly Tan/Pan:Auwps0658J (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sunil Kumar Rajwanshi, D.R. Date Of Hearing: 28 05 2025 Date Of Pronouncement: 29 05 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 271(1)(c)

after making addition of Rs.19,67,333/-. The AO, vide separate order dated ITA No.379/LKW/2024 Page 2 of 4 29.05.2019, passed under section 271(1)(c) of the Act, held that the assessee had concealed the particulars of his income amounting to Rs.19,67,33/- and accordingly sought to evade ... tune of Rs.5,08,874/-. The AO, therefore, imposed a penalty of Rs.5,09,000/- under section 271(1)(c) of the Act. 3. Aggrieved, the assessee preferred an appeal before the NFAC. However, the appeal before the NFAC came to be dismissed for the reason of non-compliance

Income Tax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karykari Sahakari Mandali Limited, Mehsana

ITA 2188/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad29 May 2025AY 2019-20

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

added to the assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given

Incometax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karyakari Sahkari Mandali Limited, Mehsana

ITA 2187/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad29 May 2025AY 2016-17

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

added to the assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given

Income Tax Officer, Ward-1, Mehsana vs. Shri Meu Juth Vividh Karyakari Sahkari Mandali Limited, Mehsana

ITA 2179/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad29 May 2025AY 2015-16

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri T.R. Senthil Kumar

Section 69A

added to the assessee's returned income under the head "Income from other sources," and penalty proceedings under section 271(1)(c) were initiated for concealment of income. 4.3 I have gone through the assessment order and record available. In the instant case, the appellant has argued that Loans given

Rupesh Mahendra Kankariya, Ahmednagar vs. ITO Ward 1, Ahmednahgar, Ahmednagar

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

ITA 465/PUN/2025[2013-14]Status: DisposedITAT Pune29 May 2025AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.465/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Rupesh Mahendra Kankariya, Vs. Ito, Ward-1, Ahmednagar. B Namrata Marbles, Tilak Road, Ahmednagar- 414001. Pan : Arspk8493L Appellant Respondent Assessee By : Miss Kimaya Kudva Revenue By Shri Milind Debaje : Date Of Hearing 22.04.2025 : Date Of Pronouncement : 29.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.08.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Of The Case & In Law, The Cit(A) Erred In; I. Concluding That The Appellant'S Request For Condonation Of Delay In Filing The Appeal Was Without Any Reasonable Cause, Rejecting The Application & Dismissing The Appeal In Limine. Ii. Dismissing The Appeal Ex-Parte Without Adjudicating The Ground Challenging Levy Of Penalty Of Appeal On Merits.

For Appellant: Miss Kimaya Kudva
Section 142(1)Section 144Section 147Section 148Section 271(1)(c)Section 274

since he was satisfied that the assessee has concealed the particulars of his income. Subsequently, show cause notice u/s 274 read with section 271(1)(c) of the IT Act was issued and served upon the assessee electronically to attend on 20.04.2022, however the assessee again remained absent and therefore

Anwar Sulthan Akbar Ali, Tiruvallur vs. ITO, Ncw-19(3), Chennai

In the result, the appeal filed by the assessee in ITA No

ITA 461/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 May 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.460 & 461/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Anwar Sulthan Akbar Ali, Vs. The Income Tax Officer, No. 5131, Mosque Road, Non Corporate Ward 19(3), Ayapakkam, Tiruvallur 600 077. Chennai. [Pan:Aonpa4265J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Shri P. Krishna Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 07.05.2025 घोषणा की तारीख /Date Of Pronouncement : 29.05.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Both Dated 20.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2013-14. 2. First, We Shall Take Up Appeal In Ita No. 460/Chny/2025 For Adjudication Of Confirmation Of Quantum Addition.

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Shri P. Krishna Kumar, JCIT
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 271Section 69A

accordance with law. Thus, the grounds raised by the assessee are allowed for statistical purposes. I.T.A. No. 461/Chny/2025 against confirmation of penalty under section 271(1)(c) of the Act. 8. We find that this appeal was filed with a delay of 14 days. The assessee filed affidavit for condonation ... against the assessment order under section 147 r.w.s. 144 r.w.s. 144B of the Act dated 25.03.2022, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for the additions made in the assessment order. Since we have remanded the quantum additions to the file

Anwar Sulthan Akbar Ali, Tiruvallur vs. ITO, Ncw-19(3), Chennai

In the result, the appeal filed by the assessee in ITA No

ITA 460/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 May 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.460 & 461/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Anwar Sulthan Akbar Ali, Vs. The Income Tax Officer, No. 5131, Mosque Road, Non Corporate Ward 19(3), Ayapakkam, Tiruvallur 600 077. Chennai. [Pan:Aonpa4265J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Shri P. Krishna Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 07.05.2025 घोषणा की तारीख /Date Of Pronouncement : 29.05.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Both Dated 20.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2013-14. 2. First, We Shall Take Up Appeal In Ita No. 460/Chny/2025 For Adjudication Of Confirmation Of Quantum Addition.

For Appellant: Shri Y. Sridhar, F.C.AFor Respondent: Shri P. Krishna Kumar, JCIT
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 271Section 69A

accordance with law. Thus, the grounds raised by the assessee are allowed for statistical purposes. I.T.A. No. 461/Chny/2025 against confirmation of penalty under section 271(1)(c) of the Act. 8. We find that this appeal was filed with a delay of 14 days. The assessee filed affidavit for condonation ... against the assessment order under section 147 r.w.s. 144 r.w.s. 144B of the Act dated 25.03.2022, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act for the additions made in the assessment order. Since we have remanded the quantum additions to the file

The Ron Taluka Primary Teachers Co-Opearative Bank Limited, Gadag vs. ACIT, Cirlce-2(1), Bangalore

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

ITA 197/BANG/2025[2016-17]Status: DisposedITAT Bangalore29 May 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2016-17

For Appellant: Shri Vinay K Kulkarni, C.AFor Respondent: Shri Subramanian S, JCIT (DR)
Section 271(1)(c)Section 40

assessee became aware of the passing of the order by the learned CIT(A) only upon receiving a penalty notice under section 271(1)(c) of the Act. Thereafter, the assessee immediately preferred an appeal to the ITAT. However, in this process, a delay of 279 days occurred. 4. Besides