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18 results for “penalty u/s 271”+ Section 302clear

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Key Topics

Addition to Income17Section 14716Transfer Pricing14Penalty13Section 143(3)12Deduction11Section 234B10Section 278Section 26

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

ITA 1600/BANG/2014[2006-07]Status: DisposedITAT Bangalore29 Nov 2018AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.V. Arvind, Standing Counsel
Section 143(3)Section 147Section 271

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

8
Section 271(1)(c)8
Section 234D8
TDS8

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

ITA 1607/BANG/2014[2006-07]Status: DisposedITAT Bangalore29 Nov 2018AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.V. Arvind, Standing Counsel
Section 143(3)Section 147Section 271

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

ITA 1608/BANG/2014[2006-07]Status: DisposedITAT Bangalore29 Nov 2018AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.V. Arvind, Standing Counsel
Section 143(3)Section 147Section 271

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

ITA 1569/BANG/2014[2006-07]Status: DisposedITAT Bangalore29 Nov 2018AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri S. Parthasarathi, AdvocateFor Respondent: Shri K.V. Arvind, Standing Counsel
Section 143(3)Section 147Section 271

penalty u/s 271 (1) (c) of I. T. Act for A. Y. 2006 – 07 and remaining two appeals are also cross appeals filed by the assessee and revenue in quantum proceedings for the same year i.e. A. Y. 2006 – 07. All these appeals were heard together and are being disposed of by this common order for the sake of convenience

MS GOOGLE INDIA PVT LTD,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BENGALURU

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 2890/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Jul 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 2301/BANG/2019[2015-16]Status: DisposedITAT Bangalore31 Jul 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 387/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 Jul 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 205/BANG/2015[2010-11]Status: DisposedITAT Bangalore31 Jul 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 68/BANG/2015[2010-11]Status: DisposedITAT Bangalore31 Jul 2023AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 559/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jul 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

DCIT, BANGALORE vs. M/S GOOGLE INDIA PVT. LTD.,, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 881/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jul 2023AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

M/S GOOGLE INDIA PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 3430/BANG/2018[2014-15]Status: DisposedITAT Bangalore31 Jul 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

penalty proceedings initiated u/s 271(1)(c) of the Act. The Appellant craves, to consider each of the above grounds of appeal independently without prejudice to one another and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 2.2 It may also be noted that wherever certain figures are recorded pertains

TELELOGIC INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

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

ITA 1599/BANG/2012[2008-09]Status: DisposedITAT Bangalore09 Mar 2016AY 2008-09

Bench: Shri Abraham P George & Shri Vijay Pal Rao

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Smt. Neera Malhotra, Addl. CIT (D.R)
Section 10ASection 133(6)Section 143(3)Section 144C(5)Section 92C(2)

penalty proceedings under section 271(1)(c) of the Act. Relief a) The Appellant prays that directions be given to grant all such relief arising from the above grounds and also all relief consequential thereto. b) The Appellant craves leave to add to or alter, by deletion, substitution, modification or otherwise, the above grounds of appeal, either before or during

M/S INFORMATICA BUSINESS SOLUTIONS PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RAGE-3, BANGALORE

In the result appeal filed by the assessee is partly allowed

ITA 3356/BANG/2018[2014-15]Status: DisposedITAT Bangalore05 Dec 2025AY 2014-15

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2014-15

For Appellant: Shri Tanmayee Rajkumar, AdvocateFor Respondent: Shri Shashi Saklani, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 234BSection 271Section 274Section 28Section 37Section 40

302 CTR 213. 3. Disallowance of provision for expenses amounting to INR 1,50,000 under section 37 of the Act The AO erred in disallowing the 'provision for contract charges' 50,985 created by the Appellant amounting to INR 1,50,000 by alleging that the same, being a provision, is an unascertained liability and contingent in nature

XLHEALTH CORPORATION INDIA PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

ITA 2311/BANG/2016[2012-13]Status: DisposedITAT Bangalore09 Feb 2018AY 2012-13

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Biswarajan Sarmal, CIT (DR)
Section 143(3)Section 92C

penalty proceedings under section 271(1)(c) of the Act. All the above grounds are without prejudice to each other. The Appellant craves leave to add, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal. The Appellant prays that appropriate relief be granted based

DCIT, BANGALORE vs. M/S GE INDIA EXPORT PVT. LTD.,, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 253/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

penalty proceeding under section 271(1)(c) of the Act which are either consequential or premature. Hence we dismiss the same as infructuous. 33. In the result, the appeal of the assessee is hereby partly allowed for statistical purposes. Coming to Revenue’s appeal in IT(TPA)A NO. 253/Bang/2016 34. The issue raised by the Revenue through Ground

GE INDIA EXPORTS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 293/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

penalty proceeding under section 271(1)(c) of the Act which are either consequential or premature. Hence we dismiss the same as infructuous. 33. In the result, the appeal of the assessee is hereby partly allowed for statistical purposes. Coming to Revenue’s appeal in IT(TPA)A NO. 253/Bang/2016 34. The issue raised by the Revenue through Ground

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

penalty proceedings under\nsection 271(1)(c) of the Act.”\nGrounds Nos. 1 to 13 raised by the Assessee are directed against\nthe transfer pricing addition. During the relevant previous year the\nAssessee provided software development services and back office\nsupport services to NTT DATA Group Companies which were utilized\nby the latter for providing services to end customers