DINESH SOMATMAL DHOKAR,MUMBAI vs. INCOME TAX OFFICER - 19(1)(1), MUMBAI

In the result, both the appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm

u/s 274 RWs 271 (1) (c) of the Act. Thus, It is apparent that notwithstanding the defective notice, the assessee was fully aware of the reason as to why the Assessing Officer sought to impose penalty. Thus, significant features of the case in hand are that penalty proceedings were initiated during the assessment proceedings. The Assessing Officer had although issued

ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-3(4), MUMBAI, MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

Accordingly.\n7. To sum-up, these Revenue's twin appeals ITA.Nos.1875 & 1872/Mum./2024 and assessee's cross objections C.O.Nos.88 & 89/MUM./2024 are dismissed in above terms

271(1)(c) of the Act. The AO relied upon the decision in the case of A M Shah & Co. vs. CIT (108 Taxman 137 (Guj)), CIT vs. Reliance Petroproduct (P) Ltd. (322 ITR 158)(SC) and Dharmendra Textiles Processors (306 ITR 277) (SC). Referring to the above mentioned judgements, the AO noted that falsity in any constituent element

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

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

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

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

158 (SC)] has elaborated the meaning of the words, 6 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited ‘furnish inaccurate particulars of income’. The relevant observations of the Hon'ble Supreme Court is extracted as under – 7. As against this, learned Counsel appearing on behalf of the respondent pointed out that the language of section 271

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

158 (SC)] has elaborated the meaning of the words, 6 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited ‘furnish inaccurate particulars of income’. The relevant observations of the Hon'ble Supreme Court is extracted as under – 7. As against this, learned Counsel appearing on behalf of the respondent pointed out that the language of section 271

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

158 (SC)] has elaborated the meaning of the words, 6 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited ‘furnish inaccurate particulars of income’. The relevant observations of the Hon'ble Supreme Court is extracted as under – 7. As against this, learned Counsel appearing on behalf of the respondent pointed out that the language of section 271

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

158 (SC)] has elaborated the meaning of the words, 6 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited ‘furnish inaccurate particulars of income’. The relevant observations of the Hon'ble Supreme Court is extracted as under – 7. As against this, learned Counsel appearing on behalf of the respondent pointed out that the language of section 271

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

158 (SC)] has elaborated the meaning of the words, 6 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited ‘furnish inaccurate particulars of income’. The relevant observations of the Hon'ble Supreme Court is extracted as under – 7. As against this, learned Counsel appearing on behalf of the respondent pointed out that the language of section 271

THE DCIT-1(3)(1) MUMBAI, MUMBAI vs. M/S FERN INFRASTRUCTURE PVT LTD, MUMBAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

u/s 271(1) (c) is leviable if either of the above-mentioned conditions are satisfied. The relevant provisions of section 271(1) (c) of the Act. are reproduced below for your reference -271(1) If the Assessing Officer or the Commissioner (Appeals) or the Commissioner in the course of any proceedings under this Act, is satisfied that any person

DCIT, CENTRAL CIRCLE - 7(1), MUMBAI , MUMBAI vs. TRIUMPH SECURITIES LTD, MUMBAI

In the result, the appeal of the revenue bearing ITA No

271(1)(c) of the Act. The\nconsequential notice under section 274 issued by the Ld.AO to assessee to offer\nhim opportunity of hearing, was specifically of notice for penalty for concealment\nof particulars of income / undisclosed income, such a notice complied with\nprinciples of natural justice and was valid under section 274 of the Act.\nAccordingly, the Ld.DR fully

EVEREST KANTO CYLINDER LTD,MUMBAI vs. DCIT CIRCLE 3(4), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Rahul Chaudhary & Shri Prabhash Shankareverest Kanto Cylinder V/S. Deputy Commissioner Of Ltd. बनाम Income Tax, Circle – 3(4), 204,Raheja Centre, Free World Trade Centre 1, Cuffe Press Journal Marg, Parade, Mumbai – 400005, Nariman Point, Mumbai – Maharashtra 400 021, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace0836F Appellant/अपीलार्थी .. Respondent/प्रतिवादी

U/s 274 of the Act was issued and secondly, there is no mention about the limb under which the penalty was proposed to be levied whether for concealment of income or for furnishing inaccurate particulars of income. So accordingly, the said notice is invalid. Considering the fact of the case, the Ld.AR informed that related to addition of bad debt

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI ,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5 (2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there

PRIYAA MOHAN GURNANI,NAVI MUMBAI vs. ITO CENTRAL CIRCLE 5(2), MUMBAI

In the result the appeal filed by the assessee stands allowed

u/s 271(1)(c) of the Act for\n assessment years under consideration can be levied, if and only\nif, there is a concealment of income or inaccurate furnishing of\nthe particulars of income.\n3.1 It was submitted that the Ld.AO made addition on account\nof notional rent. The assessee thus submitted that no penalty\ncould be levied, as there