RUBY SINGH,DELHI vs. DCIT, CC-8, DELHI

ITA 3043/DEL/2026Status: DisposedITAT Delhi31 August 2026AY 2018-193 pages
AI SummaryAllowed

What were the facts?

The assessee's appeals concerned penalties levied under Section 221(1) for three assessment years. The validity of the reopening of assessments for these years was a subject of pending appeals before the jurisdictional High Court.

What did the Tribunal hold?

The Tribunal held that the penalty under Section 221(1) could not be sustained as the issue of reopening had become debatable after its admission by the High Court. Therefore, the penalties were reversed.

What were the issues?

Whether a penalty under Section 221(1) is sustainable when the underlying assessment reopening is under challenge and admitted by the High Court.

Which sections of the Income-tax Act were involved?

Section 221(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘G’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHNADRA

For Appellant: CA Sh. Uma Shankar, Adv
Hearing: 19.08.2026Pronounced: 19.08.2026

PER SATBEER SINGH GODARA, JM These assessee’s three appeals ITA No. 3042, 3043 & 3044/Del/2026 for assessment years 2016-17, 2018-19 & 2019- 20, arise against the Commissioner of Income Tax (Appeals)-24 [in short, the “CIT(A)”], New Delhi’s orders, all dated 06.01.2026 passed in case nos. CIT(A), Delhi-24/10847/2015-16, 10391/2017-18 & 10628/2018-19 involving proceedings under ITA Nos.3042, 3043 & 3044/Del/2026

section 221(1) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); respectively. Heard both the parties at length. Case files perused.

2.

We notice at the outset during the course of hearing that the as

The order continues below.

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