RAJASTHAN URBAN DRINKING WATER SEWERAGE AND INFRASTRUCTURE CORPN LIMITED,OLD WORKING WOMEN HOSTEL, BEHIND NEHRU PALACE vs. ACIT, CIRCLE-6, JPR, NEW CENTRAL REVENUE BUILDING

ITA 654/JPR/2026Status: DisposedITAT Jaipur16 September 2026AY 2019-2010 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the penalty under section 270A cannot be imposed mechanically. The assessee's explanation for the delay was bona fide, and the income declared was accepted by the AO without variation, thus excluding it from 'under-reported income'.

What were the facts?

The assessee, a government company, did not file its return under section 139(1) due to delays in statutory audit. It later filed a return under section 148, which was accepted by the AO without additions. A penalty was levied under section 270A for under-reported income.

What were the issues?

Whether penalty under section 270A is leviable when a belated return filed under section 148 is accepted without any additions, and if the assessee's explanation for delay is considered bona fide.

Which sections of the Income-tax Act were involved?

Section 270A,Section 148,Section 139(1),Section 119(2)(b)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘SMC’ BENCH, JAIPUR

Before: Shri T.R. Senthil Kumar & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “the learned CIT(A)”] dated 05.01.2026 passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), arising out of the penalty order dated 14.08.2024 passed by the Assessing Officer (hereinafter referred to as “the AO”) under section 270A of the Act for the assessment year 2019-20. I.T.A No. 654/JPR/2026 Page No 2 Rajasthan Urban Drinking Water S

The order continues below.

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