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18 results for “penalty u/s 271”+ Section 144C(6)(C)clear

Sorted by relevance

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Key Topics

Addition to Income13Transfer Pricing12Section 143(3)10Section 80I9Section 408Deduction8Disallowance8Penalty8Comparables/TP

BRIGHTCOM GROUP LIMITED (FORMERLY KNOWN AS LYCOS INTERNET LIMITED),HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-16(1),, HYDERABAD

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

section 115). 5. Erred in initiating penalty proceedings u/s. 271(1)(c), 271AA and 271BA of the Income Tax Act. The assessee may add, alter or modify any other point to the Grounds of appeal at any time before or at the time of hearing of the appeal.” 3. The assessee also raised the additional grounds on 19.11.2019 which read

APACHE FOOTWEAR INDIA PRIVATE LIMITED,MAMBATTU VILLAGE vs. ASSISTANT COMMISSIONER OF INCOME TAX ,CIRCLE-1(1), TIRUPATI

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

ITA 385/HYD/2021[2017-18]Status: Disposed
8
Section 92C7
Section 143(1)6
Section 2715
ITAT Hyderabad
11 Jan 2023
AY 2017-18

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Kuriachan, CAFor Respondent: Shri Rajendra Kumar, CIT-DR
Section 13Section 144CSection 5

penalty notice and computation of income to the assessee instead of passing the draft assessment order. Secondly, the AO vide his communication dated 25.10.2022 had admitted that no final assessment order pursuant to the direction of the ld.DRP had been passed as the Assessing Officer had already passed the assessment order on 26.02.2021 though the Assessing Officer was required

HYUNDAI MOTOR INDIA ENGINEERING PRIVATE LIMITED,HYDERABAD vs. DCIT CIRCLE -2(1), HYDERABAD

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

ITA 197/HYD/2021[2016-17]Status: DisposedITAT Hyderabad11 Dec 2023AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: Shri Jeevan Lal Lavidiya
Section 143(3)Section 92C(3)

Section 92CA of the IT Act, directions given by DRP u/s 144C(5) of the Act and “Give Effect to Directions u/s 144C order of the TPO dt.19.03.2021, the final assessment order u/s 143(3) r.w.s. 144C(13) of the Act was passed and the total income of the assessee was assessed at Rs.49,99,97,796/-. Thereafter

ACIT., CIRCLE-5(1) , HYDERABAD vs. MARKET TOOLS & RESEARCH PRIVATE LIMITED, HYDERABAD

ITA 1935/HYD/2014[2010-11]Status: HeardITAT Hyderabad22 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH P. LTD.,),HYDERABAD vs. ACIT, CIRLCE-16(2), , HYDERABAD

ITA 501/HYD/2016[2011-12]Status: DisposedITAT Hyderabad22 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

ACIT, CIRLCE-5 (1), , HYDERABAD vs. MARKET TOOLS RESEARCH PRIVATE LIMITED , HYDERABAD

ITA 424/HYD/2016[2011-12]Status: HeardITAT Hyderabad22 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

MACROMILL RESEARCH INDIA LLP (FORMERLY MARKET TOOLS RESEARCH PRIVATE LIMITED),HYDERABAD vs. ACIT., CIRCLE-16(2), , HYDERABAD

ITA 1866/HYD/2014[2010-11]Status: DisposedITAT Hyderabad22 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri Darpan Kirpalani, C.AFor Respondent: Shri Kumar Pranav
Section 234BSection 271Section 271ASection 271BSection 40Section 92C(2)

271(1(C) of the Act. 16. Initiating penalty proceedings u/s 271BA and u/s 271AA.” 2.1. Additional grounds raised by the assessee for A.Y. 2010- 11 read as under : 17. The learned TPO has grossly erred in not appreciating that the outstanding receivables is not covered in the definition of international transaction as defined u/s

MADHUCON PROJECTS LTD, HYDERABAD,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3, HYD, HYDERABAD

ITA 1326/HYD/2015[2005-06]Status: DisposedITAT Hyderabad02 Mar 2023AY 2005-06

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

ITA 1938/HYD/2014[2006-07]Status: DisposedITAT Hyderabad02 Mar 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

MADHUCON PROJECTS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-3, HYDERABAD, HYDERABAD

ITA 1937/HYD/2014[2005-06]Status: DisposedITAT Hyderabad02 Mar 2023AY 2005-06

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Jeevan Lal Lavidiya
Section 132Section 153ASection 254(2)Section 801ASection 80I

271(1)(c) of the Act. As the Assessing Officer not passed any order for levying penalty, this ground is preposterous and cannot be adjudicated. Dismissed accordingly. 41. In the result ITA No. 1970/Hyd/2011 and 1499/Hyd/2011 are partly allowed for statistical purposes. SA Nos. 83 and 84/ Hyd/2012 are dismissed as infructuous as we have already disposed of the appeals

F5 NETWORKS INNOVATION PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-17(1), HYDERABAD

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

ITA 912/HYD/2024[2020-21]Status: DisposedITAT Hyderabad30 Jun 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Sharath Rao & ShriFor Respondent: Shri Narender Kumar Naik
Section 143(1)Section 143(3)Section 92C

144C of the Act. 33.7 It is also pertinent to highlights that the statute does not permit the collection of tax beyond what is legitimately due from the assessee. Taxation must be based on liability established under the law, and merely because of a procedural lapse, an assessee cannot be compelled to pay tax that it is not legally required

DODLA DAIRY LIMITED,HYDERABAD vs. DCIT CIRCLE -8(1), HYDERABAD

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144Section 80Section 801BSection 80J

penalty proceedings under section 270A of the Act by alleging that there is under reporting of income by the Appellant.” 3. Apart from that the assessee company has filed before us letters dated 14.07.2023, 21.09.2023 and 22.04.2025, wherein it has raised additional grounds of appeal, which reads as under: Filed on 14.07.2023: “1. On the facts and circumstances

M/S KANTAR GDC INDIA PVT. LTD. (FORMERLY TNS INDIA PVT LTD),HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 2261/HYD/2017[2013-14]Status: HeardITAT Hyderabad03 Jun 2024AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha, G.आ.अपी.सं /Ita No.2261/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2013-14) M/S. Kantar Gdc India (P) Vs. Dy. C. I. T. Ltd (Formerly Tns India (P) Circle 2(2) Ltd, Hyderabad Hyderabad Pan:Aabcn2278F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Harpreet Singh Ajmani राज" व "ारा/Revenue By:: Shri Shiva Sewak, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 15/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order

For Appellant: Advocate Harpreet Singh AjmaniFor Respondent: : Shri Shiva Sewak, CIT(DR)
Section 143(3)Section 144C(5)Section 271(1)(c)

penalty proceedings u/s 271(1)(c), 271AA, 271BA of the Act. The Appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal.” 3. Facts of the case, in brief, are that the assessee company is engaged

PRAKASH LAL POTLURI,HYDERABAD vs. INCOME TAX OFFICER, (INT TAXN)-2,HYD, HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 567/HYD/2023[2015-16]Status: HeardITAT Hyderabad29 Feb 2024AY 2015-16

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2015-16 Prakash Lal Potluri, Vs. The Income Tax Officer, Hyderabad. (International Taxation)-2, Hyderabad. Pan : Gnkpp1085B. (Appellant) (Respondent) Assessee By: None Revenue By: Sri M. Vijay Kumar – Cit-Dr Date Of Hearing: 29.02.2024 Date Of Pronouncement: 29.02.2024

For Appellant: NoneFor Respondent: Sri M. Vijay Kumar – CIT-DR
Section 142(1)Section 144Section 144C(15)Section 147Section 148Section 48

penalty proceedings under sections 271(1)(c) and 271F. Despite the assessee's explanations, the Assessing Officer did not accept, as the assessee failed to prove that he had not received the sale consideration from said Anil Kumar and added the income from the sale of land to the return of income, totaling Rs.1,20,00,000/-. 3 Accordingly

MICROSOFT GLOBAL SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

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

ITA 251/HYD/2021[2016-17]Status: DisposedITAT Hyderabad27 Mar 2024AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Nageswara Rao, AdvocateFor Respondent: Ms. N.Swapna, CIT-DR
Section 143(3)Section 154Section 271(1)(c)Section 92C

u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. Thereafter penalty proceedings under Section 271(1)(c) were 3 initiated separately due to reporting of inaccurate particulars of income. 4. Feeling aggrieved with final assessment order, assessee preferred appeal before us. 5. Before us, the ld. AR for the assessee has submitted that the assessee has approached

MADHUVALLI LAKAMRAJU,USA vs. ADIT, (INT TAXN)-1, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 294/HYD/2023[2013-14]Status: DisposedITAT Hyderabad31 Aug 2023AY 2013-14

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2018-19 Smt. Madhuvalli Vs. Adit (Int Taxn)-1, Lakamraju, California, Usa. Hyderabad. C/O. B. Narsing Rao & Co., Chartered Accountants, Jubiliee Hills, Hyderabad. Pan : Aczpl9709J. (Appellant) (Respondent) Assessee By: Shri K.C. Devdas. C.A. Revenue By: Ms. Th. Vijaya Lakshmi, Cit-Dr Date Of Hearing: 30.08.2023 Date Of Pronouncement: 31.08.2023 O R D E R Per Shri Laliet Kumar, J.M. This Appeal Is Filed By The Assessee, Feeling Aggrieved By The Directions Issued By The Income Tax Officer (Osd) & Secretary (Drp-1), Bengaluru Invoking Proceedings U/S 144C(5) Of The Income Tax Act, 1961 For The A.Y 2013-14 On The Following Grounds :

For Appellant: Shri K.C. Devdas. C.AFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 142(1)Section 144C(5)Section 147Section 148Section 271Section 68

Section 68 of the Income Tax Act, 1961. Since, the assessee failed to disclose the cash deposits, the penalty u/s 271 (i)(c) of the IT Act was separately initiated for concealment of income and passed the draft assessment order. 3.2. Feeling aggrieved, the assessee has challenged the draft order dt.17.03.2022 before the DRP. Thereafter, the DRP after considering

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (I) PRIVATE LIMITED ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

144C(5) of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel, Bangalore (“Ld. DRP”) on 05.10.2017 & 26.10.2018 for A.Ys. 2013-14 & 2014-15 respectively. Since these appeals are inter-related, they are heard together and one consolidated order is being passed for the sake of convenience and brevity. ITA Nos.32/Hyd/2019 & 2 2130/Hyd/2017

OAKTON GLOBAL TECHNOLOGY SERVICES CENTRE (INDIA) PRIVATE LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-16(2), HYDERABAD

In the result, the appeal of the assessee in ITA No

ITA 2130/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

144C(5) of the Income Tax Act, 1961 ('the Act'), as per the direction of Learned Dispute Resolution Panel, Bangalore (“Ld. DRP”) on 05.10.2017 & 26.10.2018 for A.Ys. 2013-14 & 2014-15 respectively. Since these appeals are inter-related, they are heard together and one consolidated order is being passed for the sake of convenience and brevity. ITA Nos.32/Hyd/2019 & 2 2130/Hyd/2017