CHINTAKUNTA MUNAYAGARI GOPAL,HYDERABAD vs. DCIT, CENTRAL CIRCLE-1(2), HYDERABAD

ITA 1912/HYD/2025Status: DisposedITAT Hyderabad05 August 2026AY 2011-1216 pages
AI SummaryAllowed

What were the facts?

The assessee's appeal challenges a penalty order under Section 271AAA for AY 2011-2012. The primary contention is that the penalty order is barred by limitation as per Section 275(1)(a) of the Income Tax Act.

What did the Tribunal hold?

The Tribunal held that the penalty order was indeed barred by limitation. The period of limitation for imposing penalty is six months from the end of the financial year in which proceedings were initiated or six months from the end of the month in which the order of the CIT(A) or Tribunal is received by the Pr. CIT, whichever is later.

What were the issues?

The key issue is whether the penalty order was passed within the prescribed time limit under Section 275(1)(a) of the Income Tax Act, considering the dates of the Tribunal's order and the Assessing Officer's 'giving effect' order.

Which sections of the Income-tax Act were involved?

Section 271AAA,Section 275(1)(a),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, HYDERABAD

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G

Pronounced: 05.08.2026

PER VIJAY PAL RAO, VICE PRESIDENT:

This appeal by the Assessee is directed against the order dated 06.09.2025 of the Ld. CIT(A), Hyderabad-11, Hyderabad arising from the penalty order passed u/sec.271AAA of the Income Tax Act [in short "the Act"], 1961, for the assessment year 2011-2012. 2. The Assessee has raised the following grounds of appeal:

1) The order of

The order continues below.

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