PEGASUS EVENT AND CONVENTION SERVICES ,PUNE vs. ACIT CIR-7, PUNE

PER ASTHA CHANDRA, JM :

The appeal filed by the assessee is directed against the order dated 07.11.2025 of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [“CIT(A)/NFAC”] pertaining to Assessment Year (“AY”) 2020-21. 2. Although a number of grounds have been raised by the assessee, however, these all relate to the order of the Ld. CIT(A)/NFAC in confirming the penalty of Rs.22,93,281/- levied by the Ld. Assessing Officer (“AO”) u/s 270A of the Income Tax Act, 1961 (the “Act”) for under-reporting of income vide his order dated 19.08.2025. 3. Briefly stated, the facts of the case are that the assessee firm did not furnish its return of income u/s 139 of the Act for AY 2020-21. Based on the information flagged on Insight portal by the Directorate of Income Tax (Systems), CBDT, it was found that the substantial income of the assessee chargeable to tax had escaped assessment for the AY 2020-21. The case of the assessee was reopened u/s 147 of the Act by following the mandated procedure in law. Accordingly, notice u/s 148 of the Act was issued to the assessee with the prior approval of the specified authority. In response to the said notice, the assessee furnished its return of income on 20.03.2024. Thereafter, all the letters/notices issued by the Ld. AO remained un- complied with by the assessee which led to the completion of assessment by the Ld. AO determining the total income of the assessee at Rs.1,31,25,467/- vide his order dated 25.02.2025 passed u/s 147 r.w.s. 144 r.w.s. 144B of the Act. Simultaneously, the Ld. AO initiated penalty proceedings u/s 270A of the Act for under-reporting of income. Accordingly, statutory notice(s) u/s 274 r.w.s. 270A of the Act was issued to the assessee on 25.02.2025. However, the same remained un-complied with by the assessee. Thereafter, on 02.04.2025, the Ld. AO issued show cause notice to the assessee, in response to which the assessee filed its reply on 11.04.2025 which was considered but not found to be acceptable by the Ld. AO due to the absence of any documentary evidence submitted by the assessee in support of its claim. He, therefore, proceeded to complete the penalty proceedings by imposing penalty of Rs.22,93,281/- u/s 270A of the Act for AY 2020-21 vide his order dated 19.08.2025. 4. The assessee filed appeal before the Ld. CIT(A)/NFAC with a delay which was condoned by him, however, there was non-compliance of the notices issued by the Ld. CIT(A)/NFAC to the assessee. The Ld. CIT(A)/NFAC dismissed the appeal of the assessee and confirmed the penalty levied by the Ld. AO observing that inspite of sufficient opportunities provided, the assessee failed to furnish any submission or supporting evidence in support of grounds of appeal and remained completely non-compliant during the appellate proceedings before him.

Order pronounced in the open court on 25th May, 2026. (R.K. Panda) VICE PRESIDENT पुणे / Pune; दिन ांक / Dated : 25th May, 2026. रदि Ravi Kumar Kumar Date: 2026.05.27 12:20:04 +05'30'

आदेश की प्रधिधलधप अग्रेधर्ि / Copy of the Order forwarded to : अपील र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent.

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