Patliputra Builders Limited vs. ACIT

Parties Involved

Facts Summary

The case involves appeals by Patliputra Builders Limited against the orders of the Commissioner of Income-tax (Appeals) and the Assessing Officer, levying penalties under sections 271(1)(c) and 271AAA of the Income Tax Act for assessment years 2009-10 to 2014-15. The assessee had filed settlement applications before the Income Tax Settlement Commission (ITSC), which were initially not allowed due to short payment of tax and interest. After the ITSC passed an order under Section 245D (4), the assessee paid a significant portion of the settlement amount but could not pay the remaining amount due to financial difficulties. The ITSC withdrew the immunity granted to the assessee, leading to the imposition of penalties by the Assessing Officer. The assessee challenged these penalties before the Income Tax Appellate Tribunal.…

Legal Issues

• 1. Whether the penalty under section 271(1)(c) was levied in accordance with the law.
• 2. Whether the penalty under section 271AAA was levied in accordance with the law.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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