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section 271(1)(c)

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No Penalty for Voluntary Correction of Bona fide computational mistakes During Assessment 

Income Tax : The Tribunal held that penalty under section 271(1)(c) cannot be imposed when errors are voluntarily corrected during assessment. ...

March 20, 2026 414 Views 0 comment Print

Penalties and Prosecutions Under Income tax Act, 1961

Income Tax : A summary of key penalties under the Income Tax Act for AY 2026-27, covering defaults from late filing and non-payment to misrepor...

October 28, 2025 529086 Views 4 comments Print

Penalty u/s 271(1)(c) Not Sustainable for Bona Fide 54F Claim Delayed by Builder Default: ITAT Delhi

Income Tax : ITAT Delhi held penalty u/s 271(1)(c) unsustainable as 54F exemption failed due to builder delay, not taxpayer’s fault. Full dis...

July 16, 2025 1080 Views 0 comment Print

Invalid Income-tax Section 271(1)(c) Penalty: Non-Specific Charge Legal Analysis

Income Tax : Understand why an income-tax penalty under Section 271(1)(c) is invalid if the charge isn't specified as concealment or inaccurate...

June 7, 2025 3000 Views 0 comment Print

Penalty Proceedings Deferred must be During Quantum Appeal: Legal Framework & Judicial Insights

Income Tax : Learn how taxpayers can defer income tax penalty proceedings when quantum additions are under appeal. Understand legal grounds and...

June 6, 2025 4689 Views 0 comment Print


Latest News


Easwar Committee Recommends Non-Levy Of Penalty in certain circumstances

Income Tax : The Committee recommends that the scope of Section 273B should be suitably enlarged to provide that penalty for concealment of inc...

January 21, 2016 1123 Views 0 comment Print


Latest Judiciary


Penalty Deleted as AO Failed to Specify Exact Section 271(1)(c) Charge: Delhi HC

Income Tax : The case addressed ambiguity in penalty proceedings where the specific charge was not identified. The Court upheld deletion of pen...

April 18, 2026 90 Views 0 comment Print

Penalty Quashed as Notice Failed to Specify Exact Section 271(1)(c) Charge: ITAT Raipur

Income Tax : The case involved an ambiguous penalty notice that did not clarify whether the charge was concealment or inaccurate particulars. T...

April 18, 2026 75 Views 0 comment Print

No Penalty on Estimated Bogus Purchases: ITAT Deletes U/s 271(1)(c) Levy

Income Tax : The case involved penalty on disallowance of purchases treated as non-genuine and estimated at 12.5%. Tribunal ruled that estimate...

April 18, 2026 63 Views 0 comment Print

Commission Disallowance Remanded – 133(6) Non-Response Not Sufficient; Ad-hoc Expenses Cut to 10%

Income Tax : ITAT Mumbai remanded ₹95.81 lakh commission disallowance, holding that non-response to Section 133(6) notices alone cannot justi...

April 18, 2026 51 Views 0 comment Print

CIT(A) Cannot Enhance on New Issue; JDA Additions & U/s 2(22)(e) Deletions Upheld

Income Tax : ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling cl...

April 18, 2026 192 Views 0 comment Print


Latest Notifications


Immunity under Section 270AA of Income-tax Act, 1961- CBDT Clarifies

Income Tax : Section 270AA of the Income-tax Act, 1961 (the Act) inter alia provides that w.e.f. 1 st April, 2017, the Assessing Officer, on an...

August 16, 2018 11967 Views 0 comment Print


Appeals Restored Because CIT(A) Ignored Request to Avoid Email Notices

December 5, 2025 204 Views 0 comment Print

Tribunal held that natural justice was violated when notices were sent only by email despite explicit instructions otherwise. Appeals were restored with costs, and the Assessing Officer must reconsider the case after allowing additional evidence.

Search-Based Penalties Collapsed: Additions Were Only Disallowances, Not Undisclosed Income

December 5, 2025 360 Views 0 comment Print

The Tribunal ruled that Explanation 5A applies only when the assessee is found possessing undisclosed tangible assets, which was not established. Since no such assets were discovered and the additions came from routine assessments, the penalty under section 271(1)(c) could not stand. This clarifies that the deeming fiction under Explanation 5A is not automatic.

ITAT Pune: ₹1.62 Cr u/s 68 Deleted — No “Source of Source” Needed Pre-01.04.2023

December 5, 2025 1734 Views 0 comment Print

Explains how ITAT Pune held that unsecured loans prior to 01.04.2023 do not require proving the lender’s source of funds, leading to deletion of a ₹1.62 crore addition.

Penalty Cannot Survive on Estimated Bogus Purchase Addition: ITAT Deletes 271(1)(c)

December 4, 2025 492 Views 0 comment Print

Tribunal quashed penalty where AO’s addition for alleged bogus purchases was purely estimated, emphasizing that penalties require concrete evidence of income concealment.

Escapement Below ₹50L: ITAT Quashes 148 Notice Issued After 3 Years

December 4, 2025 1053 Views 0 comment Print

ITAT Delhi held that a reassessment notice issued three years after the relevant AY is invalid if the alleged escaped income is below ₹50 lakh, reinforcing the statutory threshold protection.

Only First 142(1) Default Penalizable: ITAT Slashes Penalty and Sends Other Issues Back

December 4, 2025 786 Views 0 comment Print

The Tribunal held that only the first non-compliance under Section 142(1) could attract penalty, deleting the remaining ₹50,000 imposed for repeated defaults. It also restored penalties under Sections 271A and 271(1)(c) for fresh adjudication since they depend on the pending quantum appeal.

Tribunal Deletes ₹2.14 Crore Addition Due to Invalid Pre-Notification NFAC Action

December 4, 2025 966 Views 0 comment Print

ITAT Kolkata quashed a reassessment order, holding that NFAC had no jurisdiction before the formal notification of Section 151A. The ₹2.14 crore addition was deleted, highlighting that faceless assessments cannot be retroactively enforced.

CIT(A) Had No Material to Examine – Assessee Gets Final Opportunity to Prove Capital Source

December 3, 2025 261 Views 0 comment Print

ITAT held that absence of earlier evidence led to addition under section 68. Now, assessee allowed to submit all books, bank statements, and capital accounts, subject to compliance conditions.

Section 271(1)(c) Penalty Invalid Due to Ambiguous Satisfaction Recorded by AO

December 3, 2025 588 Views 0 comment Print

ITAT held that a penalty under Section 271(1)(c) is invalid when concealment and inaccurate particulars are invoked together without specifying the exact charge. The ruling reinforces that penalty notices must be unambiguous and legally precise.

Misapplied Circular 19/2017: Commercial Transaction Ignored – Tribunal Remands 2(22)(e) Addition 

December 3, 2025 315 Views 0 comment Print

Tribunal holds that the CBDT circular exempting commercial transactions was wrongly ignored; AO must re-verify if the shareholder loan was a genuine business accommodation before taxing under Section 2(22)(e).

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