PAWAN KUMAR AGRAWAL,JAIPUR vs. ITO TDS-2, JPR, JAIPUR

ITA 350/JPR/2026Status: DisposedITAT Jaipur22 September 2026AY 2014-20157 pages
AI SummaryAllowed

What were the facts?

The Assessing Officer (AO) initiated proceedings against the assessee for failure to collect tax at source on scrap sales. The AO issued notices and passed an order treating the assessee as being in default, raising a demand for tax, interest, and penalty. The assessee appealed, arguing the order was barred by limitation and that Section 206C was not applicable.

What did the Tribunal hold?

The Tribunal held that the AO's order was passed beyond a reasonable period of four years from the end of the financial year, making it barred by limitation. Consequently, the order of the AO and the consequential interest demand were quashed.

What were the issues?

Whether the order passed by the AO under Section 206C(6A) read with Section 206C(7) was barred by limitation. Whether the CIT(A) erred in not adjudicating the additional ground of appeal on limitation.

Which sections of the Income-tax Act were involved?

Section 206C(6A),Section 206C(7),Section 250(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri Kuldip Singh & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Additional/Joint Commissioner of Income Tax (Appeals), Panaji [hereinafter referred to as “the learned CIT(A)”] dated 30.12.2025 arising out of the order dated 15.03.2021 passed by the Income Tax Officer, TDS-2, Jaipur (hereinafter referred to as “the AO”) under section 206C(6A) read with section 206C(7) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for the financial year 2013-14 relevant to the assessment year 2014-15. 2. The grounds of appeal raised by the Assessee before us in the memorandum of appeal in Form No. 36 read as under:

“1. The learned CIT (A) fa

The order continues below.

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