BINOD KUMAR SINGH,PATNA vs. ITO, PATNA

ITA 225/PAT/2026Status: DisposedITAT Patna23 July 2026AY 2020-2111 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) did not properly consider the substantive compliance by the assessee, including paying the tax and not contesting the assessment order, despite the procedural lapse of not filing Form 68. It was also noted that the AO did not specify under which limb of Section 270A(9) the penalty for misreporting was imposed.

What were the facts?

The assessee declared income of ₹3,18,950, but interest income of ₹20,36,110 was added during reassessment. A penalty of ₹8,73,360 was levied under Section 270A for under-reporting and misreporting income.

What were the issues?

Whether the penalty for misreporting of income under Section 270A was correctly imposed, and if the assessee could be denied immunity under Section 270AA for a procedural lapse when substantive conditions were met.

Which sections of the Income-tax Act were involved?

Section 270A,Section 270AA,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA ‘DB’ BENCH AT KOLKATA

Before: SHRI YOGESH KUMAR US & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals), NFAC [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2020-21 dated 05.01.2026. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

"

1.

For that the learned Commissioner of Income Tax (Appeals), NFAC, has unjustly dismissed the appeal, ignoring the fact that the Appellant paid full amount of tax on income even before assessment order was passed hence there was no loss of revenue.

2.

For that the learned Commissioner of Income Tax (Appeals) has erred i

The order continues below.

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