https://www.taxtmi.com/caselaws?id=774526 ITAT Ahmedabad set aside penalty order u/s 271(1)(c) after quantum assessment was remanded for fresh adjudication. The tribunal held that penalty proceedings are intrinsically linked to quantum assessment outcomes and cannot be sustained when the foundational assessment is itself under re-examination. Since the coordinate bench had directed AO to verify contract nature and payment flows for fresh assessment, penalty proceedings must await quantum determination finality. The tribunal emphasized that penalty u/s 271(1)(c) requires deliberate satisfaction of statutory conditions, not automatic imposition upon additions. Appeal allowed for statistical purposes with penalty matter remanded to AO for fresh adjudication aligned with quantum reassessment outcome. en-us Fri, 04 Jul 2025 00:00:00 +0530 Thu, 10 Jul 2025 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774526 ITAT Ahmedabad set aside penalty order u/s 271(1)(c) after quantum assessment was remanded for fresh adjudication. The tribunal held that penalty proceedings are intrinsically linked to quantum assessment outcomes and cannot be sustained when the foundational assessment is itself under re-examination. Since the coordinate bench had directed AO to verify contract nature and payment flows for fresh assessment, penalty proceedings must await quantum determination finality. The tribunal emphasized that penalty u/s 271(1)(c) requires deliberate satisfaction of statutory conditions, not automatic imposition upon additions. Appeal allowed for statistical purposes with penalty matter remanded to AO for fresh adjudication aligned with quantum reassessment outcome. Case-Laws Income Tax Fri, 04 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774526