This article provides an in-depth analysis of the Income Tax Appellate Tribunal’s decision in the case of Sobh Ram vs Income Tax Officer, Ward-4, Panipat, focusing on the penalties imposed for the Assessment Year 2013-14 under section 271(1)(c) of the Income Tax Act, 1961.
The case involves an appeal filed by Sobh Ram against the penalty order issued by the ITO, Ward-4, Panipat, which was upheld by the CIT (Appeals) Karnal. The penalties were based on discrepancies found in the taxpayer’s declared income for the AY 2013-14.
The primary issue at hand was whether the penalties imposed under section 271(1)(c) for the concealment of income were justifiable. The tribunal reviewed the earlier quantum appeal that challenged the basis of the assessment order related to the cyclical pattern of deposits and withdrawals in the taxpayer’s bank account.
The tribunal noted that the quantum appeal was allowed and remanded back to the CIT(A) for a fresh decision. It directed that the penalty appeal should also be reconsidered in light of the new findings from the quantum appeal. Consequently, the penalty issue was restored to the files of the CIT(A) to be decided afresh.
This case highlights the procedural intricacies involved in the imposition of penalties under the Income Tax Act. The decision underscores the importance of ensuring that all relevant facts are thoroughly examined before penalties are confirmed.
ITA No. 1844/DEL/2020 – Sobh Ram vs ITO Ward 4, Panipat on Penalty Issues for AY 2013-14
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