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165 results for “penalty u/s 271”+ Section 54clear

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Key Topics

Addition to Income70Section 143(3)49Section 153C37Section 14837Penalty33Transfer Pricing29Disallowance29Section 133A25Section 271(1)(c)

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

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

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

Showing 1–20 of 165 · Page 1 of 9

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Section 92C22
Section 153A22
Section 14722

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

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

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis

SHRI. MUNINAGA REDDY,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for A

ITA 859/BANG/2012[2006-07]Status: DisposedITAT Bangalore12 Jan 2015AY 2006-07

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri P. Dinesh, AdvocateFor Respondent: Dr. P.K. Srihari, Addl. CIT
Section 143(3)Section 271(1)Section 271(1)(c)Section 54BSection 80C

54,572 claimed as exempt under section 54B of the Act, the Assessing Officer disallowed an amount of Rs.3,68,14,038 for not producing any evidence in respect of reinvestment claimed and restricted the exemption to an amount of Rs.6,70,40,704. Penalty proceedings u/s.271(1)(c) of the Act were initiated u/s.271

SUBBALAKSHMI KURADA ,BANGALORE vs. DEPUTY COMMISSONER OF INCOME TAX, CIRCLE-3(1)(2) , BANGALORE

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

ITA 1913/BANG/2025[2016-17]Status: DisposedITAT Bangalore15 Apr 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2016-17

For Respondent: Shri V. Narendra Sharma
Section 142Section 143(2)Section 271Section 274Section 54

section 274 rws 271 of the Act is defective as the same has been issued for both concealment of income and furnishing of inaccurate particulars of income and thus, the entire proceedings are bad in law and hence, the order passed deserves to be cancelled. 4. Without prejudice to the above, the learned CIT[A] failed to appreciate that

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(2), BANGALORE

In the result, all the appeals of the assessee are dismissed

ITA 702/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 20Section 202Section 249(3)Section 271(1)(b)Section 271(1)(c)

penalty levied u/s 271(1)(c) of the Act. There was a delay of 346 days in filing the appeal before NFAC. The assessee filed a condonation petition before NFAC explaining the reasons for the inordinate delay in filing the appeal before NFAC and the NFAC has observed as follows: “5………………..The appellant has stated that this inordinate delay

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

ITA 700/BANG/2024[2013-17]Status: DisposedITAT Bangalore04 Jun 2024AY 2013-17

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 20Section 202Section 249(3)Section 271(1)(b)Section 271(1)(c)

penalty levied u/s 271(1)(c) of the Act. There was a delay of 346 days in filing the appeal before NFAC. The assessee filed a condonation petition before NFAC explaining the reasons for the inordinate delay in filing the appeal before NFAC and the NFAC has observed as follows: “5………………..The appellant has stated that this inordinate delay

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BANGALORE

In the result, all the appeals of the assessee are dismissed

ITA 704/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 20Section 202Section 249(3)Section 271(1)(b)Section 271(1)(c)

penalty levied u/s 271(1)(c) of the Act. There was a delay of 346 days in filing the appeal before NFAC. The assessee filed a condonation petition before NFAC explaining the reasons for the inordinate delay in filing the appeal before NFAC and the NFAC has observed as follows: “5………………..The appellant has stated that this inordinate delay

THE KARNATAKA CHEMISTS & DRUGGISTS ASSOCIATION®,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1) , BANGALORE

In the result, all the appeals of the assessee are dismissed

ITA 703/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Soundararajan K.

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 20Section 202Section 249(3)Section 271(1)(b)Section 271(1)(c)

penalty levied u/s 271(1)(c) of the Act. There was a delay of 346 days in filing the appeal before NFAC. The assessee filed a condonation petition before NFAC explaining the reasons for the inordinate delay in filing the appeal before NFAC and the NFAC has observed as follows: “5………………..The appellant has stated that this inordinate delay

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

ITA 1666/BANG/2024[2017-18]Status: HeardITAT Bangalore30 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

For Appellant: Ms. Neera Malhotra CIT-D.RFor Respondent: Sri Prakash Shridhar Hegde, CA
Section 11Section 11(6)Section 250Section 270ASection 274

U/s 270A of the Act. In the opinion of ld. CIT(A)/NFAC the AO has failed to establish that any mens rea was involved & the assessee willfully misrepresented or suppressed the facts. 9.4 For the purpose of evaluating the correctness of rival submissions addressed we deem it apposite to extract section 270A of the Act herein below: 270A. Penalty

KOTARKI CONSTRUCTION PVT LTD ,BIDAR vs. JOINT COMMISSIONER OF INCOME TAX GULBARGA RANGE , GULBARGA

In the result, the appeal by the assessee is allowed

ITA 3395/BANG/2018[2010-11]Status: DisposedITAT Bangalore31 Aug 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2010-11

For Appellant: Shri Ravi Shankar, AdvocateFor Respondent: Shri Elamurugu G., Jt.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 271(1)(c)Section 274Section 40Section 43BSection 80I

54,06,759/- under the head departmental deduction U/s 43B Page 4 of 7 7 Disallowance of Deduction claimed under 2,71,454/- the head CBF 8 Disallowance of excess claim of 37,487/- depreciation 9 Disallowance of depreciation claimed in respect 2,19,231/- of Guest House 10 Disallowance of expenditure U/s

SRI. GOVINDACHARY vs. D.C.I.T,

In the result, the assessee's appeals for Assessment Years 2004-05 and 2005-06

ITA 1809/BANG/2013[2004-05]Status: DisposedITAT Bangalore10 Jul 2015AY 2004-05

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri G.S. PrashanthFor Respondent: Shri G.R. Reddy, CIT (D.R)
Section 132Section 143(3)Section 249

271(1)(c) in this case, on the basis of the appellant’s submissions. This is clearly in the knowledge of the appellant and subsequently, after having taken the stand that penalty should not be levied on account of his voluntary acceptance to the additions made for which ‘no appeal has been filed’ and after exhausting the time for levying

SRI VENKATESWARA DEVELOPERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(2)(1), BANGALORE

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1910/BANG/2019[2014-15]Status: DisposedITAT Bangalore16 Jun 2022AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Narayana K.R., DR
Section 143(3)Section 24Section 251(2)Section 271(1)(C)Section 271(1)(c)

271(1)(c). The Hon'ble High Courts have further said that it affects the contention of the revenue the in case of every return where claim made were not accepted by assessing officer for any reason the assess will invite the penalties.” 3. Ground No.1 in ITA No.1910/Bang/2019 is reproduced below: “The AO has erred in adding

SRI. VENKATESWARA DEVELOPERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(2)(1), BENGALURU

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2474/BANG/2019[2014-15]Status: DisposedITAT Bangalore16 Jun 2022AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri S.V. Ravishankar, A.RFor Respondent: Shri Narayana K.R., DR
Section 143(3)Section 24Section 251(2)Section 271(1)(C)Section 271(1)(c)

271(1)(c). The Hon'ble High Courts have further said that it affects the contention of the revenue the in case of every return where claim made were not accepted by assessing officer for any reason the assess will invite the penalties.” 3. Ground No.1 in ITA No.1910/Bang/2019 is reproduced below: “The AO has erred in adding

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 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

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

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

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

RAICHUR CITY URBAN CO-OPERATIVE BANK LTD.,,RAICHUR vs. DIT, BANGALORE

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

ITA 1147/BANG/2015[2012-13]Status: DisposedITAT Bangalore26 Apr 2017AY 2012-13

Bench: Shri Inturi Rama Raoshri Laliet Kumarraichur City Urban Co-Operative Bank Ltd., Gunj Road, Raichur-584 102. . Appellant Vs. The Dy. Director Of Income-Tax Intelligence & Criminal Investigation, Bengaluru. . Respondent Appellant By : Shri B.S Sudheendra, C.A Respondent By : Shri G Kamaladar, Standing Counsel

For Appellant: Shri B.S Sudheendra, C.AFor Respondent: Shri G Kamaladar, Standing Counsel
Section 246A(1)Section 253(1)Section 271FSection 283B

penalty of Rs.65,500/- u/s 271FA on the assessee. 4. Feeling aggrieved by the order, the assessee filed an appeal before us and has submitted that the order passed by the authority below is required to be satisfied and it was enquired by the Bench as to how the order passed by the authority Director of Income-tax (Intelligence