← All Phrases

“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)

Amish Anantrai Modi, Mumbai vs. Dy Commissioner of Income Tax Central Circle 2(1), Mumbai

ITA 4172/MUM/2024[2015-16]Status: DisposedITAT Mumbai07 May 2025AY 2015-16

Bench: him.

For Appellant: Shri Ravikant PathakFor Respondent: Shri Ram Krishn Kedia
Section 250Section 271(1)(c)

hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had dismissed the appeal against the Penalty Order, dated 15/01/2024, passed under Section 271(1)(c) of the Act for the Assessment Year 2015-2016. 2. The Assessee has raised following grounds of appeal : “1. On the facts ... Penalty Order, dated 15/01/2024, we find that the Assessing Officer had levied penalty of INR.4,29,570/- on the Assessee under Section 271(1)(c) of the Act for the Assessment Year 2015-2016 observing that despite having been granted sufficient opportunity during the penalty proceedings the Assessee had failed

Balvir Mohan Mistry, Na vs. Arivs.Income Tax Officer, Ward-1, Navsari

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 8/SRT/2025[2008-09]Status: DisposedITAT Surat06 May 2025AY 2008-09

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Mukesh Jain, CIT DR
Section 144Section 147Section 148Section 271(1)(c)

cash deposited of Rs. 15,88,800/- as the unexplained income of the assessee. Further, the Assessing Officer also initiated penalty proceedings under Section 271(1)(c) of the Act, for concealment of income. 4. In appeal, again despite issuance of various notices of hearing none appeared on behalf ... dismissed. 5.0 In result, the appeal of the appellant is Dismissed.” 5. Further, Ld. CIT(A) also confirmed levy of penalty under Section 271(1)(c) of the Act, on the assessee. 6. The assessee is in appeal before us, against the order passed by Ld. CIT(A) confirming

Balvir Mohan Mistry, Na vs. Arivs.Income Tax Officer, Ward-1, Navsari

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 7/SRT/2025[2008-09]Status: DisposedITAT Surat06 May 2025AY 2008-09

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Mukesh Jain, CIT DR
Section 144Section 147Section 148Section 271(1)(c)

cash deposited of Rs. 15,88,800/- as the unexplained income of the assessee. Further, the Assessing Officer also initiated penalty proceedings under Section 271(1)(c) of the Act, for concealment of income. 4. In appeal, again despite issuance of various notices of hearing none appeared on behalf ... dismissed. 5.0 In result, the appeal of the appellant is Dismissed.” 5. Further, Ld. CIT(A) also confirmed levy of penalty under Section 271(1)(c) of the Act, on the assessee. 6. The assessee is in appeal before us, against the order passed by Ld. CIT(A) confirming

Income Tax Officer, Ward-1(3)(1), Surat, Anavil Business Centre vs. Navinbhai Himatlal Shah, Diwali Baug Athwalines

In the result, appeal of the revenue is dismissed

ITA 115/SRT/2025[2007-08]Status: DisposedITAT Surat06 May 2025AY 2007-08

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.107 To 109/Srt/2025 Assessment Years:(2010-11 To 2012-13) (Hybrid Hearing) The Ito, Vs. Hiteshbhai Popatbhai Sakariya, Ward – 1(2)(6), 17, Hetal Nagar Society, Rander Road, Surat Near Navyug College, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akvps5306G (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025 आयकर अपील सं./Ita No.115/Srt/2025 Assessment Year:(2007-08) The Ito, Vs. Navinbhai Himatlal Shah, Ward – 1(3)(1), 7/Swashray Society, Diwali Baug, Surat Athwalines, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Cross Objection No.1/Srt/2025 [Arising In Ita No.115/Srt/2025] Assessment Year:(2007-08) Navinbhai Himatlal Shah, Vs. The Ito, 7/Swashray Society, Diwali Baug, Ward – 1(3)(1), Athwalines, Surat - 395001 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Appellant By Shri Mitul R. Mehta, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025

Section 271(1)(c)

erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false? ITA Nos.107 ... erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false

Income Tax Officer, Ward-1(2)(6), Surat vs. Hiteshbhai Popatbhai Sakariya, Surat

In the result, appeal of the revenue is dismissed

ITA 109/SRT/2025[2012-13]Status: DisposedITAT Surat06 May 2025AY 2012-13

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.107 To 109/Srt/2025 Assessment Years:(2010-11 To 2012-13) (Hybrid Hearing) The Ito, Vs. Hiteshbhai Popatbhai Sakariya, Ward – 1(2)(6), 17, Hetal Nagar Society, Rander Road, Surat Near Navyug College, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akvps5306G (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025 आयकर अपील सं./Ita No.115/Srt/2025 Assessment Year:(2007-08) The Ito, Vs. Navinbhai Himatlal Shah, Ward – 1(3)(1), 7/Swashray Society, Diwali Baug, Surat Athwalines, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Cross Objection No.1/Srt/2025 [Arising In Ita No.115/Srt/2025] Assessment Year:(2007-08) Navinbhai Himatlal Shah, Vs. The Ito, 7/Swashray Society, Diwali Baug, Ward – 1(3)(1), Athwalines, Surat - 395001 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Appellant By Shri Mitul R. Mehta, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025

Section 271(1)(c)

erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false? ITA Nos.107 ... erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false

Income Tax Officer, Ward-1(2)(6), Surat vs. Hiteshbhai Popatbhai Sakariya, Surat

In the result, appeal of the revenue is dismissed

ITA 108/SRT/2025[2011-12]Status: DisposedITAT Surat06 May 2025AY 2011-12

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.107 To 109/Srt/2025 Assessment Years:(2010-11 To 2012-13) (Hybrid Hearing) The Ito, Vs. Hiteshbhai Popatbhai Sakariya, Ward – 1(2)(6), 17, Hetal Nagar Society, Rander Road, Surat Near Navyug College, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akvps5306G (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025 आयकर अपील सं./Ita No.115/Srt/2025 Assessment Year:(2007-08) The Ito, Vs. Navinbhai Himatlal Shah, Ward – 1(3)(1), 7/Swashray Society, Diwali Baug, Surat Athwalines, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Cross Objection No.1/Srt/2025 [Arising In Ita No.115/Srt/2025] Assessment Year:(2007-08) Navinbhai Himatlal Shah, Vs. The Ito, 7/Swashray Society, Diwali Baug, Ward – 1(3)(1), Athwalines, Surat - 395001 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Appellant By Shri Mitul R. Mehta, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025

Section 271(1)(c)

erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false? ITA Nos.107 ... erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false

Income Tax Officer, Ward-1(2)(6), Surat vs. Hiteshbhai Popatbhai Sakariya, Surat

In the result, appeal of the revenue is dismissed

ITA 107/SRT/2025[2010-11]Status: DisposedITAT Surat06 May 2025AY 2010-11

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.107 To 109/Srt/2025 Assessment Years:(2010-11 To 2012-13) (Hybrid Hearing) The Ito, Vs. Hiteshbhai Popatbhai Sakariya, Ward – 1(2)(6), 17, Hetal Nagar Society, Rander Road, Surat Near Navyug College, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akvps5306G (Appellant) (Respondent) Appellant By Shri Himashu Gandhi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025 आयकर अपील सं./Ita No.115/Srt/2025 Assessment Year:(2007-08) The Ito, Vs. Navinbhai Himatlal Shah, Ward – 1(3)(1), 7/Swashray Society, Diwali Baug, Surat Athwalines, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Cross Objection No.1/Srt/2025 [Arising In Ita No.115/Srt/2025] Assessment Year:(2007-08) Navinbhai Himatlal Shah, Vs. The Ito, 7/Swashray Society, Diwali Baug, Ward – 1(3)(1), Athwalines, Surat - 395001 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afsps3575H (Appellant) (Respondent) Appellant By Shri Mitul R. Mehta, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 05/05/2025 Date Of Pronouncement 06/05/2025

Section 271(1)(c)

erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false? ITA Nos.107 ... erred in not appreciating the fact that the act of assessee clearly falls within the ambit of provisions of Explanation-1 to section 271(1)(c) of the Act as the assessee had failed to offer an explanation or which was found by the A.O. to be false

Raniwala Jewellers Private Limited, Jaipur vs. ACIT/DCIT Cir-6, Jpr, Jaipur

In the result, the appeal of the assessee is allowed

ITA 10/JPR/2025[2023-24]Status: DisposedITAT Jaipur06 May 2025AY 2023-24

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Nikhilesh Kataria, C.A., Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT, Ld. DR
Section 10BSection 10B(8)Section 139Section 139(1)Section 139(5)Section 143(1)Section 250Section 80J

several of its decisions. Hence, all that the court has to see is, what is the true effect of the language employed in section 271(1)(a) (i). If court finds that language to be ambiguous or capable of more meanings than one, then the court has to adopt that ... penalty. It must first determine what is the meaning of the expression 'the amount of the tax, if any, payable by him' in section 271(1)(a) (i). Does it mean the amount of tax assessed under section 143 or the amount of tax payable under section 156. The word

Gck Stock Private Limited, Jaipur vs. ITO WD 1(4), Jaipur

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

ITA 1572/JPR/2024[2015-2016]Status: DisposedITAT Jaipur06 May 2025AY 2015-2016
For Appellant: Shri Bhupendra Shaha, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 131Section 133(6)Section 142(1)Section 143(3)Section 148Section 148ASection 234Section 250Section 271

facts and circumstances of the case and in law, the Assessing Officer erred in charging interest u/s 234 and initiating penalty under section 271[1][c] 4) In the facts and the circumstances of law, the Ld. Commissioner of Income Tax (A) erred in dismissing appeal By totally overlooking judgment ... proceedings and confirm the addition of ₹4,96,87,796/- and uphold the interest charged under Section 234 and the penalty initiated under Section 271(1)(c)." 4. We note from the submission of the Ld AR vehemently argued that the case of the assessee is squarely covered

Sattarbhai Sulemanbhai Mansuri, Sabarkantha vs. The ITO, Ward-3, Himatnagar

In the result, the appeal is allowed for statistical purposes

ITA 469/AHD/2025[2014-15]Status: HeardITAT Ahmedabad06 May 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2014-15 Mr.Sattarbhai Sulemanbhai Mansuri Ito,Ward-3 Anjumarstrit Narth Gulam Floor Factri Vs. Himatnagar. Sarvoday Soc, Polo Ground Himatnagar Sabarkantha 383 001. (Applicant) (Responent) : Shri Varis Isani, Advocate Assessee By : Shri Ravindra, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 06/05/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Ravindra, Sr.DR
Section 139(1)Section 143(3)Section 148Section 250Section 271(1)(c)Section 50CSection 50C(1)Section 50C(2)

refer the matter to the Departmental Valuation Officer (DVO) under section 50C(2), despite the assessee’s request. Penalty proceedings under section 271(1)(c) were also initiated. 3. The assessee preferred an appeal before the CIT(A) and submitted that actual consideration received was only Rs.5,00,000/- (1/5th

Narendra Khimji Savla, Mumbai vs. Income Tax Officer Ward 6(1)(1), Mumbai

Appeal of the assessee is allowed

ITA 6567/MUM/2024[2012-13]Status: DisposedITAT Mumbai06 May 2025AY 2012-13

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Leyaqat Ali Aafaqui- Sr. DR
Section 132Section 143(2)Section 144Section 147Section 148Section 271(1)(c)Section 69ASection 69C

circumstances of the case and law, the Ld. CIT(A) erred in confirming the action of Ld AO of initiating penalty provision under section 271(1)(c).” 2. The assessee is an individual. The Assessing Officer (AO) received information from DDIT (Inv.) in respect of the assessee regarding a loan

Roshan Lal, Alwar vs. Income Tax Officer, Bhiwadi

Appeal of the assessee is allowed for

ITA 50/JPR/2025[2014-15]Status: DisposedITAT Jaipur05 May 2025AY 2014-15

Bench: The Hon'Ble Income Tax Appellate Tribunal, Jaipur.

For Appellant: Sh. Prateek BasotiaFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 142(1)Section 147Section 148Section 151(1)Section 69A

assessment, an unwarranted tax demand of ₹52,59,180/- was raised against the Appellant. Furthermore, penalty 12 Roshal Lal vs. ITO proceedings under Sections 271(1)(b), 271(1)(c), and 271F were initiated, along with the levy of interest under Sections 234A and 234B. The additions and penalties were ... interest under 13 Roshal Lal vs. ITO Section 234A and Section 234B of the Income Tax Act and in initiating penalty proceedings under Section 271(1)(b) , Section 271(1)(c) and Section 271F in respect of the addition made under Section 69A for alleged concealment of income

Pradeep Garg, Ajmer vs. ITO 2(1) Ajmer, Ajmer

ITA 397/JPR/2024[2010-11]Status: DisposedITAT Jaipur05 May 2025AY 2010-11
For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 143(3)Section 147Section 271(1)(c)Section 274Section 40A(3)Section 64(1)(iv)

arises because the assessee has challenged the levy of penalty order dated 26.03.2018. ITA No. 397/JP/2024 Pradeep Garg vs. ITO passed under section 271(1)(c) of the Income Tax Act, 1961 [ for short "Act"] by ITO, Ward 2(1), Ajmer [ for short AO]. 2. In this appeal, the assessee ... proceedings were initiated for concealment of particulars of income. He has taken the plea that penalty cannot be initiated on both limbs of section 271(1)(c). He has also pointed out that in the original (first) notice u/s.274 rws 271, issued on 28.01.2016 as well as in the subsequent

Earth Reality, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

In the result, the appeal is dismissed

ITA 460/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad05 May 2025AY 2015-16

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Earth Reality Dcit, Cir.1(1)(1) Earth-49, Vs Vadodara. Opp: Misuza Court Vasna Road, Vadodara 390 007 Pan : Aadfe 0069 N (Applicant) (Responent) Assessee By : Shri Hemant Suthar, Ar Revenue By : Ms.Bhavnasingh Gupta, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 30/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 05/05/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Hemant Suthar, ARFor Respondent: Ms.Bhavnasingh Gupta, Sr.DR
Section 133ASection 143(3)Section 250Section 271(1)(c)

under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”]) confirming the penalty levied under section 271(1)(c) by the Assessing Officer in respect of A.Y. 2015–16. Facts of the Case 2. The assessee, a partnership firm engaged in the business of real ... explanation and added Rs.14,00,000/- as unaccounted income. Assessment order became final, since no appeal filed against it Penalty proceedings under section 271(1)(c) were separately initiated, assessee failed to response to notices, therefore, vide order dated 31.10.2017, penalty of Rs.4,32,600/- was levied on the ground

Rajesh Kumar Jaiswal, Allahabad vs. Deputy/ACIT(Central), Allahabad

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

ITA 16/ALLD/2023[2018-19]Status: DisposedITAT Allahabad02 May 2025AY 2018-19

Bench: the query raised by the assessing authority vide questionnaire issued under section 142 (1) dated 23.01.2021, in assessment proceedings for the AY 2018-19.

For Appellant: Sh. Nikhil Agarwal & Ms. VidishaFor Respondent: Sh. A.K. Singh, Sr. DR
Section 115Section 115BSection 142Section 24Section 250Section 68Section 69

wherein the Hon’ble Supreme Court had held that voluntary disclosure did not release the assessee from the mischief of penal proceedings under section 271(1)(c). He particularly invited our attention to para 7 and 9 of the said order, wherein the Hon’ble Supreme Court had held that

M/S Abhman Distributor Pvt. Ltd., Kolkata vs. NFAC, Delhi

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

ITA 1410/KOL/2023[2013-14]Status: DisposedITAT Kolkata02 May 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 131Section 143(3)Section 148Section 151Section 250Section 68

assessee under section 68 of the Income tax Act, 1961 as proposed in the show cause notice issued. Along with penalty proceedings under section 271(1)(c) are being initiated for furnishing inaccurate particulars of income.” 3.1 The credits in the bank statement are mentioned at para

Nisha Baheti, Kolkata vs. ACIT, Cir-11(2), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 1199/KOL/2023[2015-16]Status: DisposedITAT Kolkata02 May 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Nisha Baheti C/O S.N. Ghosh & Associates, Acit, Cir-11(2), Advocates 2, Garstin Place, Aaykar Bhavan, P-7, 2Nd Floor, Suite No.203, Off Chowringhee Square, Vs. Hare Street, Kolkata-700001, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Ahmpb0320M Assessee By : Shri Somnath Ghosh, Ar Revenue By : Ms. Roma Chaudhary, Dr Date Of Hearing: 21.04.2025 Date Of Pronouncement : 02.05.2025

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Ms. Roma Chaudhary, DR
Section 10(38)Section 127(3)Section 142(1)Section 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

Ashok Kumar Jain, Mumbai vs. Income Tax Officer, Mumbai

In the result the appeal filed by the assessee stands allowed for statistical purpose

ITA 931/MUM/2025[2009-10]Status: DisposedITAT Mumbai02 May 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Ashokkumar Jain National Faceless Appeal R.No. 24/1, 2Nd Main Road, Centre,Delhi /19(1)(2), New Extn,Kalasipalyam, Vs. Matru Mandir, Bangalore-560002 Mumbai-400007 Pan No. Aiupj 4290 K Appellant Respondent

For Appellant: Ms. Akriti SethFor Respondent: Ms. Deepa Hiray, Sr. DR
Section 271(1)(c)

1. “The First Appellate Authority has erred on facts and in law by affirming the imposition of penalty by the Learned AO under section 271(1)(c) of the Income Tax Act, 1961 of 11,67,391/- (Rupees Eleven Lakhs Sixty-Seven Thousand Three Hundred and Ninety One only). Ashok

M/S Steel Strips Infrastructures Ltd., Chandigarh vs. ACIT, CC-II, Chandigarh

In the result, appeal of the Assessee is partly allowed

ITA 732/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh01 May 2025AY 2014-15

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 732 /Chd/2018 निर्धारण वर्ष / Assessment Year : 2014-15 M/s Steel Strips Ltd. बनाम The Asst. CIT Central Circle-II Chandigarh SCO 49-50, Sector 26, Chandigarh स्थायी लेखा सं./PAN NO: AACCS5077J प्रत्यर्थी / Respondent अपीलार्थी/Appellant निर्धारिती की ओर से / Assessee by : Shri Ashwani Kumar, C.A, Ms. Muska Garg, C.A राजस्व की ओर से / Revenue by : Shri Ved Parkash Kalia, Sr. DR सुनवाई की तारीख/ Date of Hea

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muska Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR
Section 271(1)(c)Section 28Section 36(1)(vii)Section 36(2)(i)Section 37(1)

assessee’s claim, the AO made an addition of Rs. 27,00,000/- to the returned income and initiated penalty proceedings under Section 271(1)(c) for furnishing inaccurate particulars of income. 6. Against the order of the Ld. AO the assessee went in appeal before

Pankajkumar Chimanlal Lodhiya, Rakjot vs. The ACIT, Central Circle-2, Rajkot

ITA 81/RJT/2022[2014-15]Status: DisposedITAT Rajkot30 Apr 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 250Section 271(1)(c)Section 271ASection 40

show cause, as to why an order imposing a penalty in respect of the additions confirmed above, should not be passed under section 271(1)(c) of the Income Tax Act, 1961. 4 10. In response to show-cause notice, the assessee filed his submissions, before the assessing officer, vide