PEDAPUDI PRIMARY AGRICULTURAL CO OPERATIVE CREDIT SOCIETY LIMITED,GUNTUR vs. THE INCOME TAX OFFICER, WARD-1, TENALI

ITA 525/VIZ/2026Status: DisposedITAT Visakhapatnam18 September 2026AY 2018-198 pages
AI SummaryRemanded

What were the facts?

The assessee's appeals against penalty orders were dismissed by the CIT(A) in limine, believing the dispute was settled under the Vivad Se Vishwas Scheme. However, the scheme was only applied to the assessment order demand, not the penalties.

What did the Tribunal hold?

The tribunal held that the CIT(A) erred in dismissing the appeals without adjudicating on merits, as the Vivad Se Vishwas Scheme settlement did not cover the penalty orders. The matters were remanded for fresh adjudication.

What were the issues?

Whether the Vivad Se Vishwas Scheme settlement for the assessment order demand extends immunity to penalty orders. Whether the CIT(A) was justified in dismissing appeals in limine without considering the merits.

Which sections of the Income-tax Act were involved?

Section 271E,Section 271D,Section 271B,Section 271DA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM DB-BENCH, VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G

Pronounced: 18.09.2026

PER VIJAY PAL RAO, VICE PRESIDENT:

These four appeals by the Assessee are directed against the four separate Orders all dated 24.02.2026 of the learned CIT(A)-National Faceless Appeal Centre [in short "NFAC"],

The order continues below.

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