ITO-41.3.4,MUMBAI, MUMBAI vs. URMILA SYNTEX, MUMBAI

ITA 2458/MUM/2026Status: DisposedITAT Mumbai10 September 202613 pages
AI SummaryPartly Allowed

What were the facts?

The assessee firm claimed bad debts and unsecured loans, which were disallowed during assessment. The Assessing Officer initiated penalty proceedings under Section 271(1)(c). The CIT(A) deleted the penalty, but the Revenue appealed.

What did the Tribunal hold?

The Tribunal found that the CIT(A) erred in deleting the penalty as the assessee failed to substantiate its claims and disclose all primary facts. The Tribunal restored the issue of the validity of the penalty notice to the Assessing Officer.

What were the issues?

Whether penalty under Section 271(1)(c) was rightly deleted by the CIT(A) when the assessee failed to substantiate claims and disclose facts, and the validity of the penalty notice.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 144,Section 143(2),Section 142(1),Section 36(1)(vii),Section 36(2),Section 133(6),Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI ARUN KHODPIA

Pronounced: 10.09.2026

PER SANDEEP GOSAIN, JUDICIAL MEMBER:

This appeal filed by the Revenue is directed against the order dated 05.12.2025 passed by the Ld. Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the “Ld. CIT(A)”], vide Order No. ITBA/NFAC/S/250/2025- 26/1083357633(1), for the Assessment Year (A.Y.) 2013-14. The Department has raised the following grounds of appeal:

ITA 2458/MUM/2026 URMILA SYNTEX

1) Ground Whether on the facts and in circumstanc

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 271(1)(c)

All 24,918 judgments and leading authorities on Section 271(1)(c) →

Latest GST High Court judgments

Search GST case law →