Case Law Details
Pramila Tarneja Vs DCIT (ITAT Delhi)
In a significant verdict, the Income Tax Appellate Tribunal (ITAT) Delhi has ruled that no penalty under section 271(1)(c) of the Income Tax Act shall be levied on a bonafide assessee who revises and adds interest income to their return. This decision arises from the case of Pramila Tarneja Vs. DCIT.
1. Background: The case pertains to appeals against the order of the Commissioner of Income Tax (Appeals) for the assessment years 2010-11 to 2012-13. The central issue in these appeals was the imposition of penalties under section 271(1)(c) of the Income Tax Act.
2. Common Ground: Both the appellant and the tax authorities acknowledged that the facts and circumstances of all three penalty appeals were similar. Hence, the appeal for the assessment year 2010-11 was chosen as the lead case for convenience.
3. Assessee’s Argument: The appellant argued that they had included the disputed interest income in their return of income in response to a notice under section 148 of the Act. Taxes were paid accordingly. Therefore, they contended that there was no concealment or furnishing of inaccurate particulars of income. The appellant, in person, emphasized their commitment to abide by tax laws but cited an omission by their tax consultant as the reason for the initial non-disclosure.
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