https://www.taxtmi.com/caselaws?id=767658 ITAT Mumbai upheld penalty under section 221(1) for non-payment of outstanding tax demand. Assessee claimed financial inability but failed to demonstrate good and sufficient reasons for default. Despite partial payments made before penalty levy, tribunal found no merit in assessee's submissions as section 221(1) explanation clarifies liability continues regardless of subsequent payments. AO's discretion to levy 100% penalty was deemed appropriate given assessee's income in subsequent years. CIT(A) had already granted partial relief by reducing penalty by interest amount. Remaining penalty was upheld and assessee's appeal dismissed. en-us Thu, 20 Mar 2025 00:00:00 +0530 Sat, 22 Mar 2025 08:33:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767658 ITAT Mumbai upheld penalty under section 221(1) for non-payment of outstanding tax demand. Assessee claimed financial inability but failed to demonstrate good and sufficient reasons for default. Despite partial payments made before penalty levy, tribunal found no merit in assessee's submissions as section 221(1) explanation clarifies liability continues regardless of subsequent payments. AO's discretion to levy 100% penalty was deemed appropriate given assessee's income in subsequent years. CIT(A) had already granted partial relief by reducing penalty by interest amount. Remaining penalty was upheld and assessee's appeal dismissed. Case-Laws Income Tax Thu, 20 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767658