Penalty u/s 271(1)(c) Imposed During Pendency of Quantum Appeal: ITAT Terms It Premature, Sets Aside Order

The ITAT (Income Tax Appellate Tribunal) set aside a "penalty under Section 271(1)(c)" imposed "during the pendency of a quantum appeal," terming it "premature." Section 271(1)(c) relates to penalties for concealment of income or furnishing inaccurate particulars. The tribunal clarified that such a penalty cannot be levied until the quantum of income (the actual addition or disallowance) is finally determined in an appeal. Since the appeal against the quantum addition was still pending, the penalty imposition was deemed premature and hence invalid.