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20 results for “penalty u/s 271”+ Reopening of Assessmentclear

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Key Topics

Section 14732Section 143(3)28Section 25025Penalty18Addition to Income17Section 14814Section 14413Section 271(1)(b)10Section 271(1)(c)

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 5/PAT/2024[2015-16]Status: DisposedITAT Patna22 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

8
Limitation/Time-bar6
Natural Justice5
Section 694
ITA 4/PAT/2024[2012-13]Status: DisposedITAT Patna22 Jan 2025AY 2012-13

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 412/PAT/2024[2012-13]Status: DisposedITAT Patna22 Jan 2025AY 2012-13

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 413/PAT/2024[2014-15]Status: DisposedITAT Patna22 Jan 2025AY 2014-15

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 414/PAT/2024[2014-15]Status: DisposedITAT Patna22 Jan 2025AY 2014-15

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 415/PAT/2024[2016-17]Status: DisposedITAT Patna22 Jan 2025AY 2016-17

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 6/PAT/2024[2016-17]Status: DisposedITAT Patna22 Jan 2025AY 2016-17

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 7/PAT/2024[2017-18]Status: DisposedITAT Patna22 Jan 2025AY 2017-18

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee that may be raised before the Assessing Officer and the Assessing Officer will duly adjudicate upon all the grounds taken by the assessee whether on merits or legal grounds. 11. So far as the penalty appeals relating to levy of penalty u/s. 271

YASHWANT SINGH,PATNA vs. DCIT, PATNA

In the result, the appeals of the assessee ITA Nos

ITA 416/PAT/2024[2017-18]Status: DisposedITAT Patna22 Jan 2025AY 2017-18
Section 143(3)Section 144Section 147Section 250Section 271(1)(b)

reopening of the assessment will be available to the assessee\nthat may be raised before the Assessing Officer and the Assessing Officer will\nduly adjudicate upon all the grounds taken by the assessee whether on merits\nor legal grounds.\n11. So far as the penalty appeals relating to levy of penalty u/s.\n271(1)(b)/272A

RANJEET KUMAR (INDIVIDUAL),BEGUSARAI vs. INCOME TAX OFFICER, WARD- 2 (1), BEGUSARAI

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

ITA 198/PAT/2025[2015-16]Status: DisposedITAT Patna06 Aug 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 250Section 271(1)(b)Section 271(1)(c)Section 271FSection 282Section 69

reopening of the assessment is not in accordance with provisions of law as there was no escapement within the meaning of sec. 147 of the Act. I.T.A. No.: 198/PAT/2025 Assessment Year: 2015-16 Ranjeet Kumar (Individual). 10. For that the Ld. CIT(A) has failed to appreciate the fact that entire proceedings of reassessment were void ab initio

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

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

ITA 205/PAT/2025[2014-15]Status: DisposedITAT Patna30 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(3)Section 147Section 148Section 194(7)Section 194C(6)Section 250

reopened and the Assessing Officer (“the Ld. AO”) issued a notice u/s 148, in response to ITA No.: 205/PAT/2025 Assessment Year: 2014-15 Bijay Kumar Saraf. which, the assessee did not file any return of income. Since no compliance was made to the notice issued in the course of reassessment proceedings, the Ld. AO disallowed the sums

SHARDINDU PRASAD SINGH,PATNA vs. ITO, WARD-6(4), PATNA

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

ITA 630/PAT/2024[2016-17]Status: DisposedITAT Patna15 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 250Section 271(1)(c)

penalty proceeding U/s. 271(1)(c) of the Income Tax Act, 1961 and its confirmation by the learned Commissioner of Income Tax (Appeals) by dismissing the appellant appeal in his order U/s. 250 of the Income Tax Act, 1961. This order is the subject matter of this 2nd appeal. B. APPELLANT SUBMISSION ON GROUNDS OF APPEAL Though numbers of grounds

AMIT KUMAR VERMA,PATNA vs. ITO, WARD- 6(1), PATNA

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

ITA 357/PAT/2023[2015-16]Status: DisposedITAT Patna04 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 148Section 234ASection 250Section 271(1)(c)

penalty proceedings u/s 271(1)(c) of the Income tax Act, 1961 for concealment of income. 8. For that the order of the CIT (Appeal) and assessment order passed by the Id. Assessing officer is wrong, arbitrary and unjustified in the facts and circumstances of the case and is bad in law as well as fact

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

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

ITA 321/PAT/2025[2015-16]Status: DisposedITAT Patna07 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 149Section 250Section 68Section 69A

271(1)(c) of the Act for concealment of income. 15. For that the ld. assessing officer has erred in initiating penalty proceeding under Section 271F of the Act for non filing of ITR. 16. For that the ld. assessing officer has erred in not providing the appellant the reason recorded for initiation of reassessment proceeding under Section

VINOD PANDEY,SHIV SAGAR, ROHTAS vs. INCOME TAX OFFICER, SASARAM

Accordingly, ITA No.326/Pat/2023 is allowed for statistical purposes, whereas ITA No.327/Pat/2023 is allowed

ITA 326/PAT/2023[2013-2014]Status: DisposedITAT Patna10 Dec 2024AY 2013-2014

Bench: Shri Duvvuru Rl Reddy, Vice- & Shri Sanjay Awasthii.T.A. Nos.326&327/Pat/2023 Assessment Year: 2013-14 Vinod Pandey………......…………………...........................……….……Appellant Siv Sagar, Rohtas, Bihar-821113. [Pan: Bdqpp7066M] Vs. Ito, Sasaram…………....……...…………………………………....…..Respondent

Section 147Section 148Section 250Section 271(1)(c)

penalty u/s 271(1)(c) of the Income Tax Act (hereinafter the ‘Act’) has also been levied thereon. Since the issues are interconnected, these two matters are being taken up for adjudication together. 1.1 The present appeals emanate from orders u/s 250 of the Act passed by the ld. CIT(A), NFAC. The issue in brief is that the assessee

VINOD PANDEY,SHIV SAGAR, ROHTAS vs. INCOME TAX OFFICER, WARD SASARAM

Accordingly, ITA No.326/Pat/2023 is allowed for statistical purposes, whereas ITA No.327/Pat/2023 is allowed

ITA 327/PAT/2023[2013-2014]Status: DisposedITAT Patna10 Dec 2024AY 2013-2014

Bench: Shri Duvvuru Rl Reddy, Vice- & Shri Sanjay Awasthii.T.A. Nos.326&327/Pat/2023 Assessment Year: 2013-14 Vinod Pandey………......…………………...........................……….……Appellant Siv Sagar, Rohtas, Bihar-821113. [Pan: Bdqpp7066M] Vs. Ito, Sasaram…………....……...…………………………………....…..Respondent

Section 147Section 148Section 250Section 271(1)(c)

penalty u/s 271(1)(c) of the Income Tax Act (hereinafter the ‘Act’) has also been levied thereon. Since the issues are interconnected, these two matters are being taken up for adjudication together. 1.1 The present appeals emanate from orders u/s 250 of the Act passed by the ld. CIT(A), NFAC. The issue in brief is that the assessee

SAVITA DEVI,SUPAUL, BIHAR, INDIA vs. INCOME-TAX OFFICER, WARD-3(4), SAHARSA, SAHARSA,BIHAR

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

ITA 157/PAT/2025[2015-16]Status: DisposedITAT Patna04 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 149Section 250Section 69

271(1)(b) of the Act, and on discussion with the Counsel, it transpired that the order u/s 144 of the Act dated 15.01.2024 had been passed in which the assessment had been made at ₹5.33 Crore. The email nirajkumarsingh62@gmail.com was by mistake registered on the e- ITA No.: 157/PAT/2025 Assessment Year: 2015-16 Savita Devi. filing portal which

VIDYOTMA,PATNA vs. ITO, WARD-2 (1), SITAMARHI

ITA 378/PAT/2025[2015-16]Status: DisposedITAT Patna28 Jan 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 250Section 253Section 271(1)(c)

penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961 is arbitrary, unjustified, void, ab-initio and bad in laws” 3. Brief facts of the case are that the assessment was reopened

RUBAN PATLIPUTRA HOSPITAL PRIVATE LIMITED,PATNA vs. CIT, PATNA

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

ITA 653/PAT/2024[2014-15]Status: DisposedITAT Patna26 May 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Sanjay Awasthii.T.A. No. 653/Pat/2024 Assessment Year: 2014-2015 Ruban Patliputra Hospital Private Limited,……………………………………….………Appellant 19, Patliputra Colony, Patna-800013, Bihar [Pan:Aafcr2222R] -Vs.- Nfac,…………………………………………….…...Respondent New Delhi, Appearances By: Shri A.K. Rastogi, Sr. Advocate, Appeared On Behalf Of The Assessee Sm. Rinku Singh, Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 16, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 143(2)Section 148Section 271(1)(c)Section 35A

u/s 148 of the Act, the assessee filed its ITR for AY 2014-15 on 26.04.2021. Accordingly notice under section 143(2) of the Act was issued on 29.06.2021 sending the reasons for reopening the assessment and also requiring the assessee to furnish necessary details and justification for claim of deduction under section 35AD of the Act. It was noteworthy

JITENDRA KUMAR RAY,LALGANJ, HAJIPUR vs. ITO WARD 1(3) VAISHALI, HAJIPUR

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

ITA 344/PAT/2025[2015-16]Status: DisposedITAT Patna21 Jan 2026AY 2015-16

Bench: or at the time of hearing of the Appeal. At the outset of hearing, we noted that the appeal filed by the assessee is delay by 256 days. In this regard, the assessee filed an affidavit dated 14.01.2026 stating the reasons for not filing appeal within the due date which is as under: “We enclose herewith an appeal u/s 253 of the I.T. Act 1961 against the order under section 250 of the Income Tax Act, 1961, relating to

For Respondent: Sh. Manab Adak, JCIT
Section 142(1)Section 143(2)Section 147Section 148Section 234ASection 250Section 253Section 274Section 69

reopening the case as per provisions of section 147 and accordingly complete the assessment proceedings under section 147 is wholly arbitrary, illegal and without sanction of law. 3) For that in the facts and circumstances of the case Ld. A.O. assessed the appellant arbitrarily, hurriedly and without application of mind, which is against the principal of natural justice