Case Law Analysis
|Income Tax Appellate Tribunal
Section 271(1)(c) IT Act | Penalty Cannot Be Imposed Until Quantum Assessment Is Concluded : ITAT Nagpur
The ITAT Nagpur has ruled that penalty proceedings under Section 271(1)(c) are contingent upon a final and concluded assessment, as the foundation for alleging concealment or inaccurate particulars cannot exist while the quantum remains open. This reinforces natural justice in tax litigation and protects assessees from premature punitive action before their liability is definitively determined.