STATE BANK OF INDIA NARODA ROAD BRANCH,NAROAD vs. THE JOINT COMMISSIONER OF INCOME TAX, TDS, ADDL/JT CIT TDS AHM, AHMEDABAD

ITA 2839/AHD/2026Status: DisposedITAT Ahmedabad16 September 2026AY 2017-184 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had a reasonable cause for not deducting tax at source due to the interim directions of the Madras High Court. Therefore, the penalty levied under Section 271C was not warranted.

What were the facts?

The assessee, State Bank of India, did not deduct TDS on Leave Fare Concession (LFC) payments for overseas travel, citing an interim order from the Madras High Court. The Assessing Officer levied a penalty under Section 271C for non-deduction.

What were the issues?

Whether penalty under Section 271C is leviable when the assessee acted in compliance with a High Court's interim order, and if such compliance constitutes a reasonable cause under Section 273B.

Which sections of the Income-tax Act were involved?

Section 271C,Section 273B,Section 10(5),Section 192,Section 201(1),Section 201(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “C” BENCH

Before: Shri Tapas Ram Misra & Shri R. Govindarajan

For Appellant: Shri Dinesh Nair, A.R
For Respondent: Shri Deependra Kumar, Sr. D.R

PER R. GOVINDARAJAN, ACCOUNTANT MEMBER:

The assessee has filed the appeal against the order dated 20-03- 2026 passed by Commissioner of Income Tax (Appeals), National Faceless Appeal Centre NFAC, Delhi (in short, referred to as the CIT(A)) u/s. 250 of the Income Tax Act, 1961 (herein referred to as “the Act”) relating to Assessment Year 2017-18. Condonation of delay

2.

There was delay of 79 days in filing of appeal before the Tribunal. Inadvertent administrative lapse, delay in obtaining internal approvals and administrative oversight were cited as the reasons for delay. Delay is condoned. State Bank of India Naroda Road Branch, A.Y. 2017-18

3.

The assessee

The order continues below.

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