cull out the relevant parts of
Section 271(1), Section 271(1B) and Section 274.
―271 (1) If the [Assessing Officer] or the
[Commissioner (Appeals ... penalty under section 271(1)
Sub-section (1) of Section 271 of the Income-tax Act
empowers the Assessing Officer to levy penalty for
certain
u/s 271(1)(C) is also initiated." 3.3. As per section
271 (1)(c) , the assessing officer is empowered to impose penalty ... issued under
section 271 (1)(c) is bad in law as it does not specify by
which limb of section 271 (1 )(c
passed an order u/s 271(1)(c) of the Act dated 29.03.2012 holding the
assessee guilty u/s 271(1)(c ... issued u/s 274
r.w.s. 271(1)(c) of the Act of even date, both the limbs of Sec. 271(1)(c
liable to penalty under Section 271(1)(c) ." He submitted that both the offences mentioned in Section 271(1)(c) , i.e. 'concealment ... while imposing penalty under Section 271(1)(c) , the AO has not invoked Expln. 1 to Section 271(1)(c) . But their Lordships
imposition of penalty for concealment Under Section 271(1)(c).
(iii) Explanation 4 annexed to Section 271(1)(c), presupposes taxable income with regard ... provision of Section 271(1)(c) and has stated that the provisions of Section 143(1A) are similar to Section 271(1)(c) and thereafter
penalty
proceedings are initiated/applicable and hence the penalty order is
void.
(c) The appellant prays that the penalty order passed u/s 271(1 ... under section 271 (l) ( c) of
the Income Tax Act, 1961 .
(c) The appellant prays that the penalty levied u/s 271(l)(c
disallowing the expense claimed
against exempt income u/s 14A . Penalty proceedings u/s 271(1)(c) were also
initiated ... under:
Penalty under s, 271(1)(c)--Concealment--Disallowance of claim for deduction
-- In order to attract the provisions of s, 271(1)(c), there
Submission of the assessee.
1. The ld. AO initiated the penalty proceeding u/s 271(1)(c) of Income
Tax Act in the assessment order ... Jaipur .
2. The notice U/s 271 should be specific on imposing of penalty u/s
271(1)(c) of Income
sustained in appeal would not mean that the penalty under Section 271(1)(c) could be levied. It was submitted before the CIT(A) that ... assessment proceedings and penalty proceedings were distinct and separate. In order, to levy penalty under Section 271(1)(c) , the Revenue is required to establish
under section 153A .
Section 271(1)(c) does not authorize the AO to compare the return filed under
section 139(1) and under section 153A ... section 271(1)(c) cannot be imposed. To appreciate this contention, it would
be relevant to refer to explanation 4 to section 271(1)(c
