https://www.taxtmi.com/caselaws?id=774444 ITAT Bangalore held that penalty under section 271(1)(c) cannot be automatically imposed when quantum additions are confirmed in assessment proceedings. The tribunal emphasized that assessment and penalty proceedings are distinct, with different burden of proof requirements. Citing SC precedents in Dilip N Shroff and T Ashok Pai, ITAT ruled that findings in assessment proceedings cannot be automatically adopted for penalty proceedings. The authorities failed to establish that the assessee concealed income particulars. Additionally, penalty under section 271B for non-audit was deleted as the assessee showed reasonable cause, being registered under section 12A but denied exemption benefits. All appeals were allowed in favor of the assessee. en-us Wed, 25 Jun 2025 00:00:00 +0530 Wed, 09 Jul 2025 08:50:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774444 ITAT Bangalore held that penalty under section 271(1)(c) cannot be automatically imposed when quantum additions are confirmed in assessment proceedings. The tribunal emphasized that assessment and penalty proceedings are distinct, with different burden of proof requirements. Citing SC precedents in Dilip N Shroff and T Ashok Pai, ITAT ruled that findings in assessment proceedings cannot be automatically adopted for penalty proceedings. The authorities failed to establish that the assessee concealed income particulars. Additionally, penalty under section 271B for non-audit was deleted as the assessee showed reasonable cause, being registered under section 12A but denied exemption benefits. All appeals were allowed in favor of the assessee. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774444