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50 results for “penalty u/s 271”+ Section 115Aclear

Sorted by relevance

Delhi74Mumbai50Kolkata7Ahmedabad2Bangalore2Rajkot1Dehradun1Hyderabad1

Key Topics

Permanent Establishment34Double Taxation/DTAA30Section 115A27Section 143(3)25Section 271(1)(c)24Business Income19Penalty15Transfer Pricing11Section 14A

GENERAL ELECTRIC INTERNATIONAL INC.,GURGAON vs. DCIT, INTERNATIONAL TAXATION CIRCLE 2(3)(2), MUMBAI

ITA 3498/MUM/2023[2016-17]Status: DisposedITAT Mumbai16 May 2024AY 2016-17

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Veerbhandra Mahajan
Section 142(1)Section 143(3)Section 144C(3)Section 250Section 271(1)(c)

u/s 271(1)(c) of the Act on account on furnishing of inaccurate particulars of income. b) The Appellant has provided bona fide explanation/reasonable cause in respect of additional income of INR 1,95,86,904 which has been suo moto offered to tax. c) The Appellant has provided bona fide explanation/reasonable cause in respect of 2 taxability of soft

Showing 1–20 of 50 · Page 1 of 3

9
Section 144C(5)8
Section 9(1)(vi)8
Section 234B8

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DZ BANK INDIA REPRESENTATIVE OFFICE, MUMBAI

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1160/MUM/2025[2010-11]Status: DisposedITAT Mumbai04 Feb 2026AY 2010-11

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

u/s 148 rws 147 of the Act. 4. Whether on the facts of the case and in law the Id. CIT(A) has erred in deleting the penalty by holding that the income determined after reassessment was subjective and open to interpretation, whereas the facts are different and heads of income have been confirmed by the ITAT and only

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DZ BANK INDIA REPRESENTATIVE OFFICE, MUMBAI

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1161/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Feb 2026AY 2014-15

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

u/s 148 rws 147 of the Act. 4. Whether on the facts of the case and in law the Id. CIT(A) has erred in deleting the penalty by holding that the income determined after reassessment was subjective and open to interpretation, whereas the facts are different and heads of income have been confirmed by the ITAT and only

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DZ BANK INDIA REPRESENTATIVE OFFICE, MUMBAI

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1159/MUM/2025[2009-10]Status: DisposedITAT Mumbai04 Feb 2026AY 2009-10

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

u/s 148 rws 147 of the Act. 4. Whether on the facts of the case and in law the Id. CIT(A) has erred in deleting the penalty by holding that the income determined after reassessment was subjective and open to interpretation, whereas the facts are different and heads of income have been confirmed by the ITAT and only

DEPUTY COMMISSIONER OF INCOME TAX(IT)-2(1)-2, MUMBAI, MUMBAI vs. DZ BANK INDIA REPRESENTATIVE OFFICE, MUMBAI

In the result, the appeals by the Revenue and the cross-objections by the assessee are dismissed

ITA 1158/MUM/2025[2008-09]Status: DisposedITAT Mumbai04 Feb 2026AY 2008-09

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Krishna Kumar, Sr. DR
Section 139Section 147Section 148Section 250Section 271(1)(c)

u/s 148 rws 147 of the Act. 4. Whether on the facts of the case and in law the Id. CIT(A) has erred in deleting the penalty by holding that the income determined after reassessment was subjective and open to interpretation, whereas the facts are different and heads of income have been confirmed by the ITAT and only

ACIT (IT) 2(1)(1), MUMBAI vs. CLSA LTD , MUMBAI

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

ITA 6390/MUM/2018[2011-12]Status: DisposedITAT Mumbai07 Sept 2021AY 2011-12

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadale & Co No. 222/Mum/2019 (A.Y. 2011-12) Acit (It)-2(1)(1) Vs. M/S. Clsa Ltd Room No. 1713, 17Th C/O Bmr & Associates Floor, Air India Bldg, Llp, Bmr House, 36B, Nariman Point, Dr. Rk Shirodkar Marg Mumbai – 400 021. Parel, Mumbai – 400012 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaccc4522E Appellant/Respondent .. Respondent/Appellant Appellant/Respondent By : Shri.Vijay Kumar Subramanyam. Dr Respondent/Appellant By : Shri.Paras Savla, Ar Date Of Hearing 25.06.2021 Date Of Pronouncement 07.09.2021 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal & The Assessee Has Filed The Cross Objection Against The Order Of The Commissioner Of Income Tax (Appeals)(Cit(A)) –56, Mumbai Passed U/S 271(1)(C) & 250 Of The Income Tax Act, 1961. Ita No. 6390/Mum/2018 & Co No. 222/Mum/2019 Clsa Ltd, Mumbai 2. The Assessee Has Filed The Cross Objection On The Legal Issue Of Challenging The Validity Of Penalty Notice. We Shall Take Up Cross Objection (C.O) No.222/Mum/2019 & The Facts Narrated. The Assessee Has Raised The Sole Ground Of Cross Objection.

For Appellant: Shri.Paras Savla, ARFor Respondent: Shri.Vijay Kumar
Section 115A(1)(b)Section 143(2)Section 271(1)(c)

115A(1)(b)(BB) of the Act. Against the Draft assessment order, the assessee has filed objections before the DRP. After considering the assessee submissions and findings of the A.O. the DRP has confirmed the action of the A.O. and issued directions on 22.12.2015. Further the final assessment order was passed on 29.01.2016 as per directions

DY. COMMISSIONER OF INCOME TAX, CIR 1(3)(1), INCOME TAX DEPARTMENT vs. SKATE TRADES AND AGENCIES PRIVATE LIMITED , RAICHUR STREET MUMBAI

In the result, the appeal of the assessee is dismissed

ITA 1663/MUM/2024[2017-18]Status: DisposedITAT Mumbai16 Apr 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhaildy. Commissioner Of Income Tax, Circle-1(3)(1), Room No.535, Aayakar Bhawan, M.K. Road, Churchgate ............... Appellant Mumbai - 400020

For Appellant: NoneFor Respondent: Shri Bhangepatil Pushkaraj, Sr.DR
Section 115BSection 142(1)Section 143(2)Section 250

u/s 115BBE was 30%+3% Cess as on first day of the Previous-Year i.e. 01.04.2016, therefore the tax- rate of 30%+3% Cess shall apply to the present case and not the higher rate, hence the assessment-order does not cause prejudice to the interest of revenue. The reason of projecting such a claim by assessee is that

ATOS INFORMATION TECHNOLOGY HK LTD,MUMBAI vs. DDIT (IT)1(1), MUMBAI

Appeals are allowed for statistical purposes

ITA 2137/MUM/2014[2006-07]Status: DisposedITAT Mumbai07 Apr 2016AY 2006-07

Bench: Shri Joginder Singh & Shri Rajendra

Section 144Section 144C(13)Section 147Section 271(1)(c)Section 9(1)(vi)

u/s 271(1)(c) of the Act amounting to Rs.,17,82,080/- and Rs.8,02,37,398/- respectively. 2. During hearing of these appeals, the ld. counsel for the assessee, Shri Dhanesh Bafna, contended that quantum appeal has been sent back to the file of the ld. Assessing Officer, therefore, the penalty may be deleted. On the other hand

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1978/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1979/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

THE DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 8464/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

ADIT (IT)-2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 3366/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

REFINITIV LTD.,MUMBAI vs. DDIT (I.TAXATION) RANGE 2, MUMBAI

Appeals are disposed off

ITA 5092/MUM/2004[2000-01]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-01

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 5228/MUM/2004[2000-2001]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-2001

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

REFINITIV LTD.,MUMBAI vs. ADIT (IT) RG 2(1), MUMBAI

Appeals are disposed off

ITA 3617/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

REFINITIV LTD.,MUMBAI vs. THE DY DIT (I.T) 2(1), MUMBAI

Appeals are disposed off

ITA 8348/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

DDIT (IT) 2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4550/MUM/2013[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

REFINITIV LTD.,MUMBAI vs. DCIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 1287/MUM/2009[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

ADIT (IT) RG 2, MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 5155/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate

REFINITIV LTD.,MUMBAI vs. DDIT (I.T) - 2(1), MUMBAI

Appeals are disposed off

ITA 3422/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

115A of the act. With respect to the revenue on front the agreement with ANI media, he held that the service agreement revenue on by the assessee is similar to the distribution agreement between the assessee and future India private limited and is taxable as royalty under article 13 of the India UK tax treaty taxable at the rate