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Ld.AO is not clear as on what limb penalty is to be levied, while passing penalty order under section 271 (1) (c) of the Act.Ld.CIT(A) failed to analyse these facts and therefore deserves to be set-aside. We thus, quash penalty order passed by Ld.AO.

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Sec. 271(1)(c) of Income Tax Act, 1961— Penalty — Concealment Penalty - It is clear that assessing officer intended to levy penalty for concealment, which either specified in notice nor in assessment order, therefore, entire penalty proceedings is without application of mind, thus, AO is not clear as on what limb penalty is to be levied, while passing penalty order under section 271 (1) (c), hence, penalty order quashed - DEPUTY CIT V/s G CORP PVT. LTD. - [2020] 27 ITCD Online 006 (ITAT-BANGALORE)