MEDITATION PROPERTIES PVT. LTD.,DELHI vs. ITO, WARD-16(3), NEW DELHI

PDF · subscribers
ITA 413/DEL/2020Status: DisposedITAT Delhi20 April 2026AY 2015-162 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the penalty under Section 271(1)(c) was consequential in nature. Since the corresponding quantum additions had already been deleted by a co-ordinate bench of the Tribunal, the penalty had no basis to stand.

What were the facts?

The assessee's appeal concerns a penalty levied under Section 271(1)(c) of the Income-tax Act. This penalty arose from quantum additions made during assessment proceedings. The department had imposed a penalty of Rs. 8,29,940/-.

What were the issues?

The primary issue was whether a penalty under Section 271(1)(c) could be sustained when the underlying quantum additions leading to the penalty were deleted.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 143(3)

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL

For Respondent: Ms. Ankush Kalra, Adv
Hearing: 16.04.2026Pronounced: 20.04.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.413/Del/2020 Assessment Year: 2015-16 Vs. Assistant Meditation Properties Commissioner of Private Limited Income Tax, Appeals-6, Flat No. 10, C ½ Model Aayakar Bhawan Town Laxmi Nagar District Centre Delhi- 110009 New Delhi-92 PAN: AAACM1194N (Appellant) (Respondent) Assessee by Sh. Praveen Kumar, AR Department by Ms. Ankush Kalra, Adv. Date of hearing 16.04.2026 Date of pronouncement 20.04.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)-6 [in short, the “CIT(A)”], Delhi’s order dated 26.11.2019 passed in case no. ITBA/PNL/F/271(1)(c)/2019-20/1021088850(1), involving proceedings u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties at length. Case file perused.

ITA No.413/Del/2020 2. Coming to the assesee’s instant appeal involving section 271(1)(c) penalty of Rs. 8,29,940/- arising as a result of GP estimating addition(s) etc, we sought to know the finality of the corresponding quantum proceedings in its case.

3.

Faced with this situation, we are fairly informed by both the parties that the tribunal’s earlier lower co-ordinate bench orders in the assessee’s appeal ITA No. 9394/Del/2019 dated 19.05.2025 has already deleted the aforesaid quantum addition against the department. We are of the considered view in this factual backdrop that the impugned section 271(1)(c) penalty has no legs to stand being consequential in nature. Deleted in very terms therefore.

4.

This assessee’s appeal is allowed.

Order pronounced in the open court on 20th April, 2026

Sd/- Sd/- (MANISH AGARWAL) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 20th April, 2026. Pooja Mittal/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

2 | P a g e

More judgments on Section 271(1)(c)

All 25,141 judgments and leading authorities on Section 271(1)(c) →

Recent GST High Court judgments

Search GST case law →