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48 results for “penalty u/s 271”+ Section 263clear

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Key Topics

Section 26359Section 143(3)53Section 271(1)(c)47Addition to Income42Section 153A24Penalty24Section 13218Disallowance17Section 14713

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

ITA 252/AHD/2022[2011-12]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

For Appellant: Ms Nupur Shah, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr.DR
Section 132Section 153ASection 271(1)Section 271(1)(c)

263 CTR 362 (Guj). The co-ordinate bench Tribunal in Shailesh S Patel vs. ITO (2018) 97 taxmann.com 570 (Ahmedabad Trib.) has also reiterated the aforesaid pre-requisite for formation of 'satisfaction' for the purposes of Section 153C of the Act. No averment is found from the case records that the documents seized towards excess stock did belong

Showing 1–20 of 48 · Page 1 of 3

Cash Deposit13
Section 14811
Section 69A11

DHARMENBHAI MAHENDRABHAI SUTARIA,HUF,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), , AHMEDABAD

In the result appeal of the assessee is hereby allowed

ITA 253/AHD/2022[2011-12]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

For Appellant: Ms Nupur Shah, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr.DR
Section 132Section 153ASection 271(1)Section 271(1)(c)

263 CTR 362 (Guj). The co-ordinate bench Tribunal in Shailesh S Patel vs. ITO (2018) 97 taxmann.com 570 (Ahmedabad Trib.) has also reiterated the aforesaid pre-requisite for formation of 'satisfaction' for the purposes of Section 153C of the Act. No averment is found from the case records that the documents seized towards excess stock did belong

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

ITA 251/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2009-10

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

For Appellant: Ms Nupur Shah, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr.DR
Section 132Section 153ASection 271(1)Section 271(1)(c)

263 CTR 362 (Guj). The co-ordinate bench Tribunal in Shailesh S Patel vs. ITO (2018) 97 taxmann.com 570 (Ahmedabad Trib.) has also reiterated the aforesaid pre-requisite for formation of 'satisfaction' for the purposes of Section 153C of the Act. No averment is found from the case records that the documents seized towards excess stock did belong

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

Section 271AAC(1) in the reassessment order, however wrongly issued penalty notice u/s. 271(1)(c) of the Act. Therefore we are of the considered opinion, the revisionary jurisdiction invoked u/s. 263

VIKAS VIJAY GUPTA,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby\ndismissed

ITA 404/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad27 May 2025AY 2017-18

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No. 404/Ahd/2024\nAssessment Year 2017-18\nVikas Vijay Gupta\nPrincipal Commissioner\n604 Sarap,\nof Income Tax,\nOpp. Navjivan Press Vs Ahmedabad-1,\nP.O. Navjivan,\nAhmedabad\nAhmedabad-380014,\nGujarat\n(Respondent)\nPAN: AEOPG6723L\n(Appellant)\nAssessee Represented: Shri Jaimin Shah, A.R.\nRevenue Represented: Shri R. N. Dsouza, CIT-DR\nDate of hearing : 27-02-2025\nDate of pronouncement : 27-05-2025\nआदे

Section 115BSection 147Section 263Section 271Section 271(1)(c)Section 271ASection 274Section 69A

271(1)(c) of the Act and\nissue a fresh penalty notice u/s 271AAC(1) of the Act. Needless to\nmention, the A.O. may levy penalty or keep the proceedings in abeyance\ntill the outcome of Ld. CIT(A)'s order on the issue of addition u/s 69A of\nthe Act. with this, I set aside the notice issued u/s

DEPUTY COMMISSIONER OF INCOME TAX, VADODARA vs. GUJARAT STATE ELECTRICITY CORPORATION LIMITED, VADODARA

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1289/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad07 Mar 2025AY 2011-12

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 271Section 271(1)(c)

penalty u/s. 271(1)(c) is not warranted. It is undisputed fact that the adjustment was made by passing assessment order dated 02-12-2016 u/s. 143(3) r.w.s. 263 of the Act which is prior to 01-04-2016. Thus the question of invoking Explanation 4 to sub-section

JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

ITA 1907/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2014-15

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Rignesh Das, CIT- D.RFor Respondent: Shri Rignesh Das, CIT- D.R
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 263

u/s 263 as well as consequential orders passed subsequent to revision proceeding are Null and VOID and deserves to be quashed and set aside. The same please be held accordingly. 5. The order passed by the learned CIT (Appeals) is bad in law and contrary to the provisions of law and facts. It is submitted that the same be held

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. PINAC STOCK BROKERS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 858/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad04 Feb 2025AY 2011-12

Bench: Dr.Brr Kumar & Shri T.R Senthil Kumar

For Appellant: Shri Deepak R Shah, ARFor Respondent: Shri R N Dsouza, CIT.DR
Section 271(1)(c)Section 275Section 68

u/s. 263 of the Act by giving effect to the quantum order. For ready reference section 275 [1A] is reproduced as under: I.T.A No. 858/Ahd/2024 A.Y. 2011-12 Page No 7 DCIT Vs. Pinac Stock Brokers Pvt. Ltd. “… [(1-A) In a case where the relevant assessment or other order is the subject matter of an appeal to the Commissioner

ASSISSTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1), VADODARA, VADODARA vs. RADHIKA JEWELLERS, VADODARA

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1263/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133ASection 271(1)(c)

section 271(1)(c) of the Act. 3. Aggrieved against the penalty order, assessee filed an appeal before Ld. CIT(A) who deleted the penalty by holding that additional income surrendered by the assessee during the survey action and the same was declared in the regular Return of Income which was I.T.A No. 1263/Ahd/2025 A.Y. 2013-14 3 ACIT

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 470/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad08 May 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

263. In this reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 450/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 May 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

263. In this reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 449/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 May 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

263. In this reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed

INCOME TAX OFFICER WARD 411 AHMEDABAD, AHMEDABAD vs. SHARANAM REALITY PRIVATE LIMITED, AHMEDABAD

In the result, the appeal preferred by the Revenue is dismissed

ITA 1839/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3)Section 263Section 271(1)(c)Section 43C

penalty order under Section 271(1)(c) of the Act. As the quantum appeal filed against the order u/s ITA Nos.1838 & 1839/Ahd/2025 (Assessment Year: 2015-16) ITO vs. Sharanam Reality P. Ltd. Page 5 of 5 143(3)/263 of the Act dated 31.03.2022 was allowed in favour of the assessee, consequent to quashing of the proceeding u/s 263

INCOME TAX OFFICER WARD-4(1)(1) AHMEDABAD, AHMEDABAD vs. SHARANAM REALITY PRIVATE LIMITED, AHMEDABAD

In the result, the appeal preferred by the Revenue is dismissed

ITA 1838/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3)Section 263Section 271(1)(c)Section 43C

penalty order under Section 271(1)(c) of the Act. As the quantum appeal filed against the order u/s ITA Nos.1838 & 1839/Ahd/2025 (Assessment Year: 2015-16) ITO vs. Sharanam Reality P. Ltd. Page 5 of 5 143(3)/263 of the Act dated 31.03.2022 was allowed in favour of the assessee, consequent to quashing of the proceeding u/s 263

VADODARA ENVIRO CHANNEL LTD.,(FORMERLY KNOWN AS EFFLUENT CHANNEL PROJECT LTD.),VADODARA vs. ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2),, VADODARA

In the result, the appeals filed by the Assessee are allowed for statistical purposes

ITA 2094/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad25 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

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

u/s 271(1)(c) was levied by him vide order dated 19-06- I.T.A Nos. 2387/Ahd/15 & 2094/Ahd/17 A.Y. 2011-12 Page No 3 Vadodara Enviro Channel Ltd. vs. ACIT 2015 (which is subject matter of ITA No. 2387/Ahd/2015). Subsequently, the AO provided another opportunity of being heard to the assessee and then levied a penalty of Rs.1

VADODARA ENVIRO CHANNEL LTD. (FORMERLY KNOWN AS EFFLUENT CHANNEL PROJECT LTD.),,BARODA vs. THE ACIT.,CIRCLE-1(2),, BARODA

In the result, the appeals filed by the Assessee are allowed for statistical purposes

ITA 2387/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad25 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

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

u/s 271(1)(c) was levied by him vide order dated 19-06- I.T.A Nos. 2387/Ahd/15 & 2094/Ahd/17 A.Y. 2011-12 Page No 3 Vadodara Enviro Channel Ltd. vs. ACIT 2015 (which is subject matter of ITA No. 2387/Ahd/2015). Subsequently, the AO provided another opportunity of being heard to the assessee and then levied a penalty of Rs.1

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

ITA 2412/AHD/2025[2013-2014]Status: DisposedITAT Ahmedabad27 Mar 2026AY 2013-2014

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 131Section 143(3)Section 68

u/s 271(1)(c) of the Act even though the quantum appeal had not yet been decided by him. 35. We have heard the rival contentions and perused the material on record. In the interest of justice, we hereby restore the matter to the file of CIT(Appeals) for de-novo consideration and he may take up the appeal

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

ITA 2413/AHD/2025[2014-2015]Status: DisposedITAT Ahmedabad27 Mar 2026AY 2014-2015

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 131Section 143(3)Section 68

u/s 271(1)(c) of the Act even though the quantum appeal had not yet been decided by him. 35. We have heard the rival contentions and perused the material on record. In the interest of justice, we hereby restore the matter to the file of CIT(Appeals) for de-novo consideration and he may take up the appeal

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

ITA 2339/AHD/2025[2012-2013]Status: DisposedITAT Ahmedabad27 Mar 2026AY 2012-2013

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 131Section 143(3)Section 68

u/s 271(1)(c) of the Act even though the quantum appeal had not yet been decided by him. 35. We have heard the rival contentions and perused the material on record. In the interest of justice, we hereby restore the matter to the file of CIT(Appeals) for de-novo consideration and he may take up the appeal

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

ITA 2420/AHD/2025[2015-2016]Status: DisposedITAT Ahmedabad27 Mar 2026AY 2015-2016

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 131Section 143(3)Section 68

u/s 271(1)(c) of the Act even though the quantum appeal had not yet been decided by him. 35. We have heard the rival contentions and perused the material on record. In the interest of justice, we hereby restore the matter to the file of CIT(Appeals) for de-novo consideration and he may take up the appeal