OCTAGON NIRMAN PRIVATE LIMITED,BHUBANESWAR, ODISHA vs. INCOME TAX OFFICER, ITO, WARD BARGARH

ITA 412/CTK/2026Status: DisposedITAT Cuttack29 June 2026AY 2013-144 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the invocation of Section 269SS for the assessment year 2013-14 was illegal as the definition of 'specified sum' was substituted by the Finance Act, 2023, effective from 01.04.2023. Therefore, the penalty order and the CIT(A)'s order were quashed.

What were the facts?

The assessee did not file its return of income for AY 2013-14. The AO noted cash deposits and initiated proceedings. The assessee claimed the cash was advance for a real estate project, but the AO imposed a penalty for accepting cash exceeding Rs. 20,000.

What were the issues?

Whether the penalty under Section 271D for violation of Section 269SS is sustainable when the relevant definition of 'specified sum' was amended prospectively.

Which sections of the Income-tax Act were involved?

Section 269SS,Section 271D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CUTTACK “DB” BENCH

Before: SHRI LAXMI PRASAD SAHU & SHRI YOGESH KUMAR U.S.

For Appellant: Shri Aditya Agarwal, FCA
For Respondent: Shri Vijay Singh, Sr. DR
Hearing: 24.06.2026Pronounced: 29.06.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

This Appeal is filed by the Assessee against the order of the NFAC, Delhi [“the Ld. CIT(A)”, for short], dated 17.02.2026 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the assessment year 2013-14. 2. Brief facts of the case as mentioned in the Order of the Ld. CIT(A) is as under: - “The appellant did not file its return of income for A.Y.2013-14. As per the information available on record, the A.O. noted that the assessee had deposited cash amounting to Rs.1,22,20,000/- in HDFC Bank, Bargarh Branch, Bargarh. Therefore, the A.O. issued notice u/s. 148 on 30.03.2021. In response the assessee did not file

The order continues below.

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