#section 271(1)(c)
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No concealment of income by the assessee if addition is merely based on deeming provision of sec 50C

No penalty u/s 271(1)(C), when the taxable income and tax remains the same after adjusting the addition due to concealment

Penalty u/s 271(1)(C) not leviable if substantial question of law exists

Penalty u/s 271(1)(c) leviable for failure to prove genuineness of exemption u/s 54

No malafide intention no penalty

Voluntarily surrender of income can’t escape penalty if assessee deliberately not shown unaccounted income in return

TP adjustment for intra group services not sustainable where receipt of services & its benefits are beyond any doubt

Revised return with same info is furnishing of inaccurate particulars

Levy of Penalty & Factors affecting Levy of Penalty including Nature of Offence, Mens Rea & Bona fide belief

Penalty Proceedings can’t be initiated in the Absence of Proper Investigation

If assessee admits undisclosed income, substantiate manner & paid taxes on undisclosed income no penalty u/s 271AAA can be levied

Penalty u/s 271(1)(c) in search assessment is tenable only if some incriminating material found during search

271(1)(c) : Penalty can be imposed on undisclosed bank accounts based on peak credits theory

271(1)(c) : Penalty cannot be imposed merely because assessee didn’t objected to addition
Explore the latest section 271(1)(c) updates on TaxGuru, including relevant Income-tax Act provisions, rules, notifications, circulars, judicial decisions and compliance guidance. The coverage highlights important tax positions, procedural requirements, assessments, deductions, penalties and litigation developments to help taxpayers and professionals understand the practical implications of changes in income-tax law.
