3I INFOTECH DIGITAL BPS LIMITED FORMERLY KNOWN AS 3I INFOTECH BPO LTD.,DELHI vs. ACIT, 25(1), DELHI

ITA 5195/DEL/2024Status: DisposedITAT Delhi24 July 2025AY 2014-14Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal, following judicial precedents, held that the limitation period for completing penalty proceedings under Section 275(1)(c) starts from the date the Assessing Officer makes a reference to the Addl. CIT for initiation of penalty. As the penalty order was passed beyond six months from this initiation date (10.10.2016), it was deemed barred by limitation and thus bad in law.

What were the facts?

The assessee appealed against penalty orders under Section 271C for AY 2014-15 and 2015-16, arguing they were barred by limitation. The penalty proceedings were initiated based on a reference from the ACIT on 10.10.2016, but the show-cause notice was issued on 10.07.2017, and the penalty order was passed beyond six months from the reference date.

What were the issues?

Whether the penalty orders passed under Section 271C of the Income-tax Act, 1961, were barred by limitation, specifically regarding the correct starting point for calculating the six-month period under Section 275(1)(c).

Which sections of the Income-tax Act were involved?

Section 271C,Section 274(1),Section 275(1)(c),Section 269T,Section 269SS,Section 271E

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Income Tax Appellate Tribunal, DELHI BENCH ‘C’: NEW DELHI

Before: SHRI S. RIFAUR RAHMAN & SHRI ANUBHAV SHARMA

For Appellant: Shri Ved Jain, Advocate, Shri Aman Garg, CA
For Respondent: Shri Om Prakash, Sr. DR
Hearing: 07.05.2025

PER S.RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

These appeals are filed by the assessee against the order of ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as ‘ld. CIT (A)] dated 10.06.2024 for Assessment Years 2014-15 and 2015-16. 2. Since the issues are common and the appeals are connected, therefore, the same are heard together and being disposed off by this common order.

3.

At the outset of the hearing, ld. AR of the assessee brought to our notice that penalty proceedings under section 271C of the Income-tax Act, 1961 (for short ‘the Act’) in the cas

The order continues below.

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