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“Section 275(1)(c)”

Section References (mined)Section 275Section 275(1)(c)181 judgments

The decision most relied on for Section 275(1)(c) is CIT v. Eli Lily & Co. (312 ITR 225), cited in 221 judgments on BharatTax.

Leading authorities on Section 275(1)(c)

CIT v. Eli Lily & Co.
312 ITR 225 · 2009 · Supreme Court
221
citing judgments

Section 195 of the Income Tax Act, which mandates tax withholding on payments to non-residents, applies only to sums that are otherwise chargeable to tax under the Act. Tax withholding provisions are not charging provisions.

CIT v. Hissaria Bros.
291 ITR 244 · 2007 · High Court
132
citing judgments

Penalty proceedings for defaults under Sections 269SS and 269T are independent of assessment proceedings; therefore, the limitation period under Section 275(1)(c) for imposing such penalties is not contingent on the completion of appellate quantum proceedings.

Pr. CIT v. Golden Peace Hotels and Resorts (P) Ltd.
124 Taxmann.com 249 · 2021 · Supreme Court
105
citing judgments

A penalty levied under Section 271(1)(c) is not sustainable if the notice issued under Section 274 fails to specifically mention whether the charge relates to concealment of income or furnishing inaccurate particulars of income. The Assessing Officer must specify the exact charge for the penalty to be valid.

Sanjay Sawhney v. Principal Commissioner of Income-tax
116 Taxmann.com 701 · 2020 · High Court
87
citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

Principal Commissioner of Income-tax\n(Central)-2 v. Mahesh Wood Products (P.) Ltd.
394 ITR 312 · 2017 · High Court
86
citing judgments

The date of initiation of penalty proceedings for the purpose of Section 275(1)(c) is when the Assessing Officer records a satisfaction or recommends penalty, not the later date when the Joint/Additional Commissioner of Income Tax issues the penalty notice.

CIT v. Hissaria Brothers
386 ITR 719 · 2016 · Supreme Court
68
citing judgments

The relevant date for determining the limitation period under Section 275(1)(c) for passing penalty orders under Sections 271D and 271E is the date of passing the assessment order.

CIT v. Jai Laxmi Rice Mills Ambala City
64 Taxmann.com 75 · 2015 · Supreme Court
49
citing judgments

For initiating penalty proceedings under Section 271D or 271E, the Assessing Officer must record satisfaction in the assessment order; non-recording of such satisfaction is fatal to the penalty.

Grihalakshmi Vision v. Assistant Commissioner of Income Tax
379 ITR 100 · 2015 · High Court
42
citing judgments

The satisfaction of the Assessing Officer is not a prerequisite for the initiation of penalty proceedings. Penalty proceedings initiated by the Joint Commissioner of Income Tax are valid. The date of the show cause notice by the penalty imposing authority is relevant for computing limitation for imposing penalty under Section 271DA.

Judgments citing Section 275(1)(c)

Mass Awash Private Limited, Lucknow vs. Addi. CIT International Taxation, Noida

In the result, the appeals of the assessee are dismissed

ITA 165/DEL/2021[2004-05]Status: DisposedITAT Delhi02 May 2023AY 2004-05

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 156Section 195Section 201(1)Section 271C(1)(a)Section 275(1)(C)Section 275(1)(c)

facts and legal aspects of the case. 2. That penalty imposed is barred by time in terms of provisions of Section 275(1)(C). 3. That the penalty order is bad in law because penalty order passed by the Additional Commissioner of Income Tax, International Taxation, Noida is said ... penalty order and the order passed u/s 201(1)/201(1A) of the Act. The contention of the appellant is that under Section 275(1)(c) of the Act, no order imposing penalty can be passed after expiry or financial year in which the proceedings in the course of which

Mass Awash Private Limited, Lucknow vs. Addi. CIT International Taxation, Noida

In the result, the appeals of the assessee are dismissed

ITA 164/DEL/2021[2006-07]Status: DisposedITAT Delhi02 May 2023AY 2006-07

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandra

For Appellant: NoneFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 156Section 195Section 201(1)Section 271C(1)(a)Section 275(1)(C)Section 275(1)(c)

facts and legal aspects of the case. 2. That penalty imposed is barred by time in terms of provisions of Section 275(1)(C). 3. That the penalty order is bad in law because penalty order passed by the Additional Commissioner of Income Tax, International Taxation, Noida is said ... penalty order and the order passed u/s 201(1)/201(1A) of the Act. The contention of the appellant is that under Section 275(1)(c) of the Act, no order imposing penalty can be passed after expiry or financial year in which the proceedings in the course of which

Shri Anjay Surana, Durg vs. Income Tax Officer, Ward-1(1), Bhilai

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 75/RPR/2022[2017-18]Status: DisposedITAT Raipur28 Apr 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 75/Rpr/2022 "नधा"रण वष" / Assessment Year : 2017-18 Anjay Surana, Jawahar Chowk, Durg, Chhatisgarh-491 001 Pan : Ajkps7430F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bhilai ……""यथ" / Respondent

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(3)Section 263

आयकर अपील"य अ"धकरण "यायपीठ रायपुर म"। IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI RAVISH

Jagdish Chandra Suwalka, Jaipur vs. JCIT, Range-7, Jaipur

In the result, appeal of the assessee is allowed

ITA 376/JPR/2022[2015-16]Status: DisposedITAT Jaipur28 Apr 2023AY 2015-16

Bench: HON’BLE SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Ms Monisha Choudhary (Addl. CIT)
Section 143(1)Section 143(2)Section 143(3)Section 269SSection 271DSection 44A

competent authority for imposition of penalty under section 271D or 271E. Therefore, the limitation for completion of penalty proceedings as provided under section 275(1)(c) has got to be computed from the date of issue of show-cause notice by the competent authority, which in the present case ... amount to repayment of loan or deposits within the meaning of section 269SS or section 269T, and on the ground that limitation under section 275(1)(c) applies to such proceedings, we hold in favour of the respondent....” For the same reason section 275 (1)(b) is also not applicable

Delhi State Taxi Operators Co-Operative Thrift Credit & Services Society Ltd, New Delhi vs. JCIT Range - 60, New Delhi

ITA 3108/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Apr 2023AY 2013-14

Bench: Shri Shamim Yahya & Ms. Astha Chandra

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri T. James Singson, CIT-DR
Section 269SSection 271DSection 271ESection 275

271D and 271E of the Act on grounds, inter alia that these have been imposed after the expiry of limitation period provided under section 275(1)(c) of the Act. Vide write up dated 24.10.2018 submitted before the Ld. CIT(A), the assessee gave brief facts on the functioning ... first penalty notice was issued on 04.05.2016 and the penalty order was passed on 24.04.2017 which is barred by limitation as provided under section 275(1)(c) of the Act. As per section 275(1)(c) no order of penalty can be passed after the expiry of the financial year

Delhi State Taxi Operators Co-Operative Thrift Credit & Services Society Ltd, New Delhi vs. JCIT Range - 60, New Delhi

ITA 3107/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Apr 2023AY 2013-14

Bench: Shri Shamim Yahya & Ms. Astha Chandra

For Appellant: Shri C.S. Aggarwal, Sr. AdvocateFor Respondent: Shri T. James Singson, CIT-DR
Section 269SSection 271DSection 271ESection 275

271D and 271E of the Act on grounds, inter alia that these have been imposed after the expiry of limitation period provided under section 275(1)(c) of the Act. Vide write up dated 24.10.2018 submitted before the Ld. CIT(A), the assessee gave brief facts on the functioning ... first penalty notice was issued on 04.05.2016 and the penalty order was passed on 24.04.2017 which is barred by limitation as provided under section 275(1)(c) of the Act. As per section 275(1)(c) no order of penalty can be passed after the expiry of the financial year

Hindustan Coca-Cola Beverages Co. P.Ltd, Gurugram vs. JCIT, Range-74, New Delhi

Accordingly, the stay application is dismissed as

ITA 3018/DEL/2022[2005-06]Status: DisposedITAT Delhi17 Jan 2023AY 2005-06

Bench: Shri Shamim Yahya & Ms. Astha Chandraआ.अ.सं/.I.T.A No.3018/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Vs. Co. P. Ltd., Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent & Stay Appl. No.413/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Co. P. Ltd., Vs. Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 201Section 250(6)Section 271CSection 275(1)(c)Section 40

penalty order passed by the Ld. AO is barred by limitation in terms of the second limb of the section 275(1)(c) of the Act since the penalty order has been passed after six months from the end of the month in which the penalty proceedings were initiated ... date on which the AO recommended the initiation of penalty proceedings was taken to be the relevant date as far as Section 275(1)(c) was concerned. There was no explanation for the delay of nearly five years in the ACIT acting on the said recommendation. The Court held that

Parivar Television Pvt. Ltd., Surat vs. The Dy. Commissioner of Income Tax, Circle-2(1)(1), Surat

In the result, the second additional ground of appeal is allowed

ITA 1738/AHD/2016[01-04-95 to 19-12-01]Status: HeardITAT Surat03 Jan 2023

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Parivar Television Pvt. Ltd., D.C.I.T., Pasrag Apartment, Near Badekha Circle-2(1)(1), Vs. Chakla Police Chowky, Surat. Momnawad, Gopipura, Surat-395001 Pan No. Aabcp 5942 J Appellant/ Assessee Respondent/ Revenue

Section 254(1)Section 271DSection 275(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND DR. ARJUN LAL SAINI

Ramakrishna Murali, Bangalore vs. Income Tax Officer, Ward-6(3)(1), Bangalore

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

ITA 975/BANG/2022[2012-13]Status: DisposedITAT Bangalore30 Dec 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri Raghavendra Chakravarthy, A.RFor Respondent: Shri K.R. Narayana, D.R
Section 143(3)Section 250Section 271D

which action for imposition of penalty is initiated, whichever period expires later.]” 6.1 The instant case falls in the third category of section 275(1)(c) of the Act and the first part of this section 275(1)(c) of the Act have no application and it was only

Rajesh Suresh Vernekar, Davangere vs. The Income Tax Officer, Ward-1(5), Davangere

In the result, all the appeals of the assessee are dismissed and copy of the order should be placed in all the respective files

ITA 991/BANG/2022[2012-13]Status: DisposedITAT Bangalore22 Nov 2022AY 2012-13

Bench: George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. Shantha Veeranna Abbigeri, AdvocateFor Respondent: Shri. K. R. Narayana, Addl. CIT(DR)
Section 139(1)Section 139(4)Section 143(1)Section 250Section 271FSection 274Section 274FSection 275(1)(c)

also submitted that the assessee filed return of income voluntarily and order passed by the AO is beyond the limit prescribed as per section 275(1)(c) of the Act. He also ITA Nos.991 to 994/Bang/2022 Page 4 of 7 submitted that while the return was processed under section

Triumph Securities Ltd, Mumbai vs. Additional CIT Cen Cir 6, Mumbai

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

ITA 1218/MUM/2018[2000-01]Status: DisposedITAT Mumbai14 Oct 2022AY 2000-01

Bench: Sri Prashant Maharishi, Am & Sri Pavan Kumar Gadale, Jm

For Appellant: Shri Rajiv Khandelwal, ARFor Respondent: Shri Dr. P Daniel, DR
Section 142Section 143(3)Section 271Section 271DSection 271E

penalty dated 30th July 2004 are bad in law in as much as the same is passed beyond the time limit prescribed under section 275(1)(c) of the Act. The learned Authorized Representative submitted that this additional ground of appeal goes to the root of the matter legal ... section 271E of the Act was issued on 15thDecember 2003 and penalty is imposed on 30thJuly 2004. He referred to the provisions of section 275(1)(c) of the Act and submitted that imposition of penalty was taken on 5th ITA Nos.1217 & 1218/Mum/2018 Triumph Securities ltd; Assessment Year

Triumph Securities Ltd, Mumbai vs. Additional CIT Cen Cir 6, Mumbai

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

ITA 1217/MUM/2018[2000-01]Status: DisposedITAT Mumbai14 Oct 2022AY 2000-01

Bench: Sri Prashant Maharishi, Am & Sri Pavan Kumar Gadale, Jm

For Appellant: Shri Rajiv Khandelwal, ARFor Respondent: Shri Dr. P Daniel, DR
Section 142Section 143(3)Section 271Section 271DSection 271E

penalty dated 30th July 2004 are bad in law in as much as the same is passed beyond the time limit prescribed under section 275(1)(c) of the Act. The learned Authorized Representative submitted that this additional ground of appeal goes to the root of the matter legal ... section 271E of the Act was issued on 15thDecember 2003 and penalty is imposed on 30thJuly 2004. He referred to the provisions of section 275(1)(c) of the Act and submitted that imposition of penalty was taken on 5th ITA Nos.1217 & 1218/Mum/2018 Triumph Securities ltd; Assessment Year

Sameer Noorullah Khan, Mumbai vs. Commissioner of Income Tax (A), Mumbai

In the result, appeal by the assessee is allowed

ITA 518/MUM/2022[2015-16]Status: DisposedITAT Mumbai16 Aug 2022AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Sameer Noorullah Khan Cit (A)-32 K Raheja Prime Kautilya Bhavan, Office No.9, 9 Th Floor, 9Th Floor, Behind Times Square Bldg, Room No.945, Bkc, Vs. Sag Baug Road, Marol Naka, Bandra (E) Andheri (East) Mumbai-400 50 Mumbai-400 059 (Appellant) (Respondent) Pan No. Alrpk 5260 A Assessee By : Shri Vimal Punmiya, Ar Revenue By : Shri Tejinder Pal Singh Anand, Dr Date Of Hearing: 16.08.2022 Date Of Pronouncement : 16.08.2022

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Tejinder Pal Singh Anand
Section 138Section 143(3)Section 250Section 269SSection 271DSection 273BSection 68

with section 269SS of the Act is initiated for accepting the loans of ₹18 lacs in cash. 012. According to the provisions of Section 275(1)(c) of the Act, no order for imposing the penalty shall be passed after the expiry of the financial year in which the proceedings

DCIT Cen Cir 7(3), Mumbai vs. Kesarinandan Township P.Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 2581/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2022AY 2010-11
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

section 275(1)(a) of the Act would not be applicable to the penalties u/s 271D of the Act and the provisions of section 275(1)(c) would only be attracted. This is also relevant for another ratio that the period will be counted from the date of assessment order ... Court/Tribunals that the provisions of clause (a) of section 275(1) of the Act would not apply and in alternative, the provisions of section 275(1)(c) only be attracted in the matters of penalties levied u/s 271D/271E of the Act. Further, it is also held that the limitation period

DCIT Cen Cir 7(3), Mumbai vs. Kesarinandan Township P.Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 2580/MUM/2017[2010-11]Status: DisposedITAT Mumbai30 Jun 2022AY 2010-11
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

section 275(1)(a) of the Act would not be applicable to the penalties u/s 271D of the Act and the provisions of section 275(1)(c) would only be attracted. This is also relevant for another ratio that the period will be counted from the date of assessment order ... Court/Tribunals that the provisions of clause (a) of section 275(1) of the Act would not apply and in alternative, the provisions of section 275(1)(c) only be attracted in the matters of penalties levied u/s 271D/271E of the Act. Further, it is also held that the limitation period

DCIT Cen Cir 7(3), Mumbai vs. Sumangla Developers P. Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 1483/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jun 2022AY 2012-13
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

section 275(1)(a) of the Act would not be applicable to the penalties u/s 271D of the Act and the provisions of section 275(1)(c) would only be attracted. This is also relevant for another ratio that the period will be counted from the date of assessment order ... Court/Tribunals that the provisions of clause (a) of section 275(1) of the Act would not apply and in alternative, the provisions of section 275(1)(c) only be attracted in the matters of penalties levied u/s 271D/271E of the Act. Further, it is also held that the limitation period

DCIT Cen Cir 7(3), Mumbai vs. Sumangla Developers P. Ltd, Mumbai

In the result, all the captioned appeals preferred by revenue stands dismissed and the CO of the assessee also stands dismissed

ITA 1482/MUM/2017[2012-13]Status: DisposedITAT Mumbai30 Jun 2022AY 2012-13
For Appellant: Shri Vijay MehtaFor Respondent: Shri Chhotarary (Special Counsel)
Section 269SSection 269TSection 271DSection 271E

section 275(1)(a) of the Act would not be applicable to the penalties u/s 271D of the Act and the provisions of section 275(1)(c) would only be attracted. This is also relevant for another ratio that the period will be counted from the date of assessment order ... Court/Tribunals that the provisions of clause (a) of section 275(1) of the Act would not apply and in alternative, the provisions of section 275(1)(c) only be attracted in the matters of penalties levied u/s 271D/271E of the Act. Further, it is also held that the limitation period

ITO - 1(1)(3), Mumbai vs. M/S Film Waves Combines P. Ltd., Mumbai

In the result, the appeal filed by the revenue is hereby dismissed and cross objection filed by the assessee is hereby allowed

ITA 170/MUM/2021[2010-11]Status: DisposedITAT Mumbai29 Apr 2022AY 2010-11

Bench: Shri Amarjit Singh, Jm & Amarjit Singh, Am आयकर अपील सं/ I.T.A. No. 170/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2010-11) Ito-1(1)(3) बिधम/ M/S. Film Waves Combines Room No.531A, 5Th Floor, Pvt. Ltd. Vs. 7Th Floor, Mehta Mahal, Aayakar Bhavan, M. K. Opera House, Mumbai- Road, Mumbai-400020. 400004. & Cross Objection No.10/Mum/2022 आयकर अपील सं/ I.T.A. No. 170/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2010-11) M/S. Film Waves Combines बिधम/ Ito-1(1)(3) Room No.531A, 5Th Floor, Pvt. Ltd. Vs. 7Th Floor, Mehta Mahal, Aayakar Bhavan, M. K. Opera House, Mumbai- Road, Mumbai-400020. 400004. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacf2525Q (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Revenue By: Shri Achal Sharma (Dr) Assessee By: Shri P.P. Bhandari सुनवाई की तारीख / Date Of Hearing: 28/02/2022 घोषणा की तारीख /Date Of Pronouncement: 29/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Revenue As Well As Assessee Have Filed The Above Mentioned Appeal As Well As Cross-Objection Against The Order Dated 24.09.2020 Passed By The Commissioner Of Income Tax (Appeals)-48, Mumbai [Hereinafter C.O. No.10/Mum/2022 A.Y.2010-11 Referred To As The “Cit(A)”] Relevant To The A.Y.2010-11 In Which The Penalty Levied By The Ao Has Been Ordered To Be Deleted.

For Appellant: Shri P.P. BhandariFor Respondent: Shri Achal Sharma (DR)
Section 143(3)Section 269SSection 271DSection 273BSection 274

amount to repayment of loan or deposits within the meaning of section 269SS or section 269T, and on the ground that limitation under section 275(1)(c) applies to such proceedings, we hold in favour of the respondent.” 6. Subsequently, the matter came into the consideration of Hon’ble Supreme

Nkc Projects (P) Ltd., Gurgaon vs. JCIT, Range-76, New Delhi

ITA 803/DEL/2018[2011-12]Status: DisposedITAT Delhi18 Nov 2021AY 2011-12

Bench: Shri Anil Chaturvedi & Shri Kuldip Singh

For Appellant: Shri Lalit Mohan, CAFor Respondent: Shri Manu Chaurasiya, Senior DR
Section 2Section 200(3)Section 201Section 201(1)Section 272Section 272A(2)(K)Section 272A(2)(k)

date of letter sent by AO recommending initiation of the penalty proceedings by returning following findings :- “Held, dismissing the appeals, that under section 275(1)(c) of the Income-tax Act, 1961, the starting point of "initiation" of penalty proceedings, would be the date on which the Assessing Officer wrote ... date of the letter sent by the Assessing Officer recommending "initiation" of the penalty proceedings. In the assessee's case, the limitation under section 275(1)(c) began to run on July 23, 2012 and the last date for passing the penalty orders was January 31, 2013. Therefore, the penalty

Green Valley Infracity Pvt. Ltd., Noida vs. ITO, Ward- 1(4), Noida

In the result, appeal of the assessee is allowed

ITA 5978/DEL/2019[2012-13]Status: DisposedITAT Delhi08 Jun 2021AY 2012-13

Bench: Sh. Anil Chaturvedi(Through Video Conferencing) Green Valley Infracity Pvt. Vs. Ito Ltd., C/O. Nitesh Singh, Ward-1(4), C-190, Sector-49, Noida Noida-201301 Pan : Aafcp 8389 P (Appellant) (Respondent) Assessee By Shri Sunil Kumar Tyagi, C.A. Revenue By --None-- Date Of Hearing: 03/06/2021 Date Of Pronouncement: 08/06/2021 Order Per Anil Chaturvedi, Am:

Section 143(3)Section 271(1)(c)Section 274Section 275(1)(c)Section 68Section 69Section 69C

erred in law and facts by sustaining the penalty imposed on the appellant vide order dated 29TH April 2019 passed by invoking section 275(1)(c) of the Income tax Act, 1961 3 (“the Act”) for Assessment year 2012-13 without appreciating the facts that the appeal against the penalty