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774 results for “penalty u/s 271”+ Section 92Cclear

Sorted by relevance

Delhi338Mumbai210Bangalore84Pune38Kolkata32Ahmedabad32Hyderabad13Chennai8Indore6Jaipur6Surat2Cochin2Chandigarh1Calcutta1Karnataka1

Key Topics

Transfer Pricing83Section 92C77Section 143(3)64Addition to Income58Section 271(1)(c)52Comparables/TP52Penalty41Section 92C(3)28Disallowance28Section 144C

COMMISSIONER OF INCOME TAX (IT & TP) vs. M/S. DONGFANG ELECTRIC CORPORATION

ITAT/66/2018HC Calcutta09 Jul 2021

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani

Section 132(1)Section 132(4)Section 133ASection 139Section 153ASection 271(1)(c)Section 274

u/s 274 of the Act, we are not dealing with the 11 other arguments made on merits of the orders imposing penalty on the assessee. 12. Aggrieved with the aforesaid order of the ITAT, the appellant/revenue has filed the present appeal. Submissions 13. Learned counsel for the appellant submits that the penalty for both the assessment years was lawfully imposed

DCIT - (LTU) - 1 , MUMBAI vs. RELIANCE INDUSTRIES LTD., MUMBAI

Showing 1–20 of 774 · Page 1 of 39

...
22
Deduction22
TP Method15

In the result, the appeals filed by the Revenue and Cross Objections filed by the assessee are dismissed

ITA 6267/MUM/2018[2009-10]Status: DisposedITAT Mumbai04 Mar 2020AY 2009-10

Bench: Shri G. Manjunatha & Shri Ravish Sood

For Appellant: Shri Jitendra Yadav &For Respondent: Shri H.N. Singh (CIT-DR)
Section 271(1)(c)Section 92C

271(1)(c) and section 92C, the penalty u/s section 271(1)(c) can be levied only if the exercise

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 731/JPR/2018[2010-11]Status: DisposedITAT Jaipur19 Dec 2018AY 2010-11
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

92C and in the manner prescribed under that section, in good faith and with due diligence and accordingly, falls under the exception carved out in the said explanation for non-imposition of penalty u/s 271

VAIBHAV GLOBAL LIMITED,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5, JAIPUR

In the result, the penalty is directed to be deleted and appeal of the assessee is allowed

ITA 730/JPR/2018[2009-10]Status: DisposedITAT Jaipur19 Dec 2018AY 2009-10
For Appellant: Shri Vijay Mehta (C.A.) &For Respondent: Smt. Roli Agarwal (CIT)
Section 143(3)Section 271(1)(c)Section 92C

92C and in the manner prescribed under that section, in good faith and with due diligence and accordingly, falls under the exception carved out in the said explanation for non-imposition of penalty u/s 271

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1389/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2007-08
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

u/s 271(1)(c) of the Act levying penalty of " 89,90,233/- on the ground of furnishing inaccurate particulars of income. 8. In the appeal against the penalty order passed by the AO, the Ld. CIT(Appeals) dismissed the assessee’s appeal with the following observations: Decision: The contention of the Appellant is not accepted for tin following reasons

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1390/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2008-09
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

u/s 271(1)(c) of the Act levying penalty of " 89,90,233/- on the ground of furnishing inaccurate particulars of income. 8. In the appeal against the penalty order passed by the AO, the Ld. CIT(Appeals) dismissed the assessee’s appeal with the following observations: Decision: The contention of the Appellant is not accepted for tin following reasons

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1392/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2010-11
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

u/s 271(1)(c) of the Act levying penalty of " 89,90,233/- on the ground of furnishing inaccurate particulars of income. 8. In the appeal against the penalty order passed by the AO, the Ld. CIT(Appeals) dismissed the assessee’s appeal with the following observations: Decision: The contention of the Appellant is not accepted for tin following reasons

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1391/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2009-10
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

u/s 271(1)(c) of the Act levying penalty of " 89,90,233/- on the ground of furnishing inaccurate particulars of income. 8. In the appeal against the penalty order passed by the AO, the Ld. CIT(Appeals) dismissed the assessee’s appeal with the following observations: Decision: The contention of the Appellant is not accepted for tin following reasons

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

ITA 928/AHD/2017[2008-09]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2008-09

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Shri S. N. Soparkar, Sr
Section 10BSection 115JSection 14ASection 271(1)(c)

92C of the Income-tax Act,1961 (the Act) and in the manner pre-scribed under that section and the relevant Rules in good faith and with due diligence as per Explanation 7 to Section 271(1) of the Act. 3.4 The learned CIT(A) grossly erred in confirming the penalty levied by the AO without appreciating that

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

ITA 921/AHD/2017[2008-09]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2008-09

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Shri S. N. Soparkar, Sr
Section 10BSection 115JSection 14ASection 271(1)(c)

92C of the Income-tax Act,1961 (the Act) and in the manner pre-scribed under that section and the relevant Rules in good faith and with due diligence as per Explanation 7 to Section 271(1) of the Act. 3.4 The learned CIT(A) grossly erred in confirming the penalty levied by the AO without appreciating that

DCIT CIRCLE-10(1), NEW DELHI vs. HTC INDIA PVT LTD, GURGAON

In the result, the appeal of the Revenue is dismissed

ITA 1785/DEL/2020[2011-12]Status: DisposedITAT Delhi30 May 2024AY 2011-12

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: NoneFor Respondent: Sh. Vivek Kr. Upadhyay, Sr. DR
Section 271(1)Section 271(1)(c)Section 92BSection 92C

92C and such price was computed as per the manner prescribed under that section in good faith and due diligence. This divulges that penalty u/s 271

RNT ASSOCIATES PRIVATE LIMITED,MUMBAI vs. DCIT CIRCLE 3(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 5221/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Oct 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2011-12

For Appellant: Mr. Vishal ShahFor Respondent: 29/10/2025
Section 143(3)Section 271(1)(c)

section 92C of the IT Act 1961. Penalty proceeding u/s 271 1961. Penalty proceeding u/s 271 (1) (c) of the IT Act is also

SMARTSTREAM TECHNOLOGIES INDIA P.LTD,MUMBAI vs. DCIT 8(3), MUMBAI

In the result, appeal filed by assessee is allowed

ITA 6297/MUM/2014[2008-09]Status: DisposedITAT Mumbai23 Jan 2018AY 2008-09

Bench: Shri G.S. Pannu & Shri Pawan Singhm/S Smartstream Technologies Dcit 8(3), India Pvt. Ltd. Aver Plaza, Aayakar Bhavan, M.K. Road, 2Nd Floor, Plot No. B-13, Mumbai-400020. Vs. New Link Road, Andheri (W), Mumbai – 400 053. Pan: Aaacq2086M (Appellant) (Respondent)

For Appellant: Shri Milin Thakore (AR)For Respondent: Shri Saurabh Deshpande
Section 143(3)Section 250Section 253Section 254(1)Section 271Section 271(1)(c)Section 274Section 92C

92C of the Act, in good faith and with due diligence and therefore explanation 7 to section 271(1)(c) of the Act was attracted, 4. The learned CIT(A) erred in not appreciating the submissions made by the appellant in correct perspective. 5. The appellant prays that the penalty of Rs.29,36,705 levied under Section 271

MITSUI PRIME ADVANCED COMPOSITES INDIA PVT. LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, the appeal is allowed

ITA 550/DEL/2016[2010-11]Status: DisposedITAT Delhi28 Apr 2016AY 2010-11

Bench: Shri R.S. Syal, Am & Shri C.M. Garg, Jm Assessment Year : 2010-11

For Appellant: Shri Kanchan Kaushal, CA &For Respondent: Shri Amrendra Kumar, CIT, DR
Section 271(1)(c)

92C and such price was computed as per the manner prescribed under that section in good faith and due diligence. This divulges that penalty u/s 271

CLESTRA LIFE SCIENCES P.LTD,MUMBAI vs. ITO WD 10(3)(1), MUMBAI

In the result, the assessee’s appeal for A

ITA 6962/MUM/2014[2002-03]Status: DisposedITAT Mumbai02 Sept 2016AY 2002-03

Bench: Shri Shailendra Kumar Yadav & Shri Jason P. Boazm/S. Clestra Life Sciences P. Ltd. Ito, Ward 10(3)(1) (Formerly As Brahma Drugs P. Ltd.) 4Th Floor, Aayakar Bhavan ‘A’ Wing. 604 Delphi Orchid Vs. M.K. Road, Mumbai 400020 Avenue, Hiranandani Business Park, Powai, Mumbai 400076 Pan - Aaacb5795L Appellant Respondent

For Appellant: Shri Jitendra SanghviFor Respondent: Shri Sher Singh
Section 143(3)Section 271(1)(c)Section 274Section 80HSection 92C

u/s 271(1)(c) of the I.T. Act. The contentions and submissions of the appellant are being discussed and decided here in under: i. ............................. ii. With reference to penalty imposed on account of adjustment of Rs.3,86,810/- made on the basis of transfer pricing provisions it was stated that entire international transactions were accepted by TPO except

PR.COMMISSIONER OF INCOME TAX-2, vs. SINOSTEEL INDIA PVT. LTD.

ITA/825/2018HC Delhi03 Aug 2018

Bench: HON'BLE MR. JUSTICE SANJIV KHANNA,HON'BLE MR. JUSTICE CHANDER SHEKHAR

Section 260ASection 271(1)(c)Section 92C

u/s 271(1)(c) has been provided in the Explanation-7 itself then the first requirement for escaping from the levy of penalty u/ s 271(1)(c), against the addition made as per the provisions of section 92C

SITEL INDIA LTD,MUMBAI vs. DCIT RG 8(3), MUMBAI

In the result the appeal of the assessee is allowed

ITA 1675/MUM/2013[2006-07]Status: DisposedITAT Mumbai08 Nov 2019AY 2006-07

Bench: Shri Shamim Yahya (Am) & Shri Pawan Singh (Jm) Sitel India Ltd. Dcit, Range-8(3), Room No. 217, 2Nd Floor, 501, Wing A &B, Boomerang, Chandivali Farm Vs Aayakar Bhavan, M.K. Marg, Road, Andheri (E) Mumbai-400020 Mumbai-400 072 Pan : Aafcs1297M Appellant Respondednt

Section 154Section 271Section 271(1)(c)Section 92C

penalty u/s. 271(l)(c) of the Act. The price charged or paid in such 4 ITA 1675/Mum/2013 transaction was computed in accordance with the provisions contained in Section 92C

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 1916/MUM/2024[2012]Status: DisposedITAT Mumbai22 Oct 2024

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

For Appellant: Mr. Rajesh SanghaviFor Respondent: 20/08/2024
Section 271GSection 92Section 92CSection 92D

section 92C(1). of the method prescribed under section 92C(1). 38. The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice prevailing in the in the diamond industry separate identity of the diamond

PROCTER & GAMBLE HYGIENE AND HEALTH CARE LTD,MUMBAI vs. DCIT 8(2), MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 1373/MUM/2015[2006-07]Status: DisposedITAT Mumbai20 Dec 2023AY 2006-07

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.1373/Mum/2015 (A.Ys. 2006-07 & 2008-09) Procter & Gamble Hygiene Vs. Dcit, Circle 10(3)(2) & Healthcare Limited Aaykar Bhavan, P & G Plaza Cardinal Mumbai Gracias Road, Chakkala, Andheri (East) Mumbai – 400099 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar &For Respondent: Tushar Mohite
Section 143(3)Section 271(1)(c)Section 274Section 80Section 801BSection 80ISection 92C

penalty u/s. 271(1)(c) of the Income-tax Act, 1961 ('the Act) of Rs 11.34,45,500 in respect of the Transfer Pricing adjustment on account of export of finished goods. 2. In doing so he failed to appreciate and ought to have held that: a) the Appellant had computed the price paid in the international transaction in accordance

PROCTER & GAMBLE HYGIENE AND HEALTHCARE LTD,MUMBAI vs. DCIT CIRCLE-8(2), MUMBAI

In the result, both the appeals of the assessee are allowed

ITA 1702/MUM/2018[2008-09]Status: DisposedITAT Mumbai20 Dec 2023AY 2008-09

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.1373/Mum/2015 (A.Ys. 2006-07 & 2008-09) Procter & Gamble Hygiene Vs. Dcit, Circle 10(3)(2) & Healthcare Limited Aaykar Bhavan, P & G Plaza Cardinal Mumbai Gracias Road, Chakkala, Andheri (East) Mumbai – 400099 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar &For Respondent: Tushar Mohite
Section 143(3)Section 271(1)(c)Section 274Section 80Section 801BSection 80ISection 92C

penalty u/s. 271(1)(c) of the Income-tax Act, 1961 ('the Act) of Rs 11.34,45,500 in respect of the Transfer Pricing adjustment on account of export of finished goods. 2. In doing so he failed to appreciate and ought to have held that: a) the Appellant had computed the price paid in the international transaction in accordance