CIVIL TECHNOLOGIES INDIA PRIVATE LIMITED,BENGALURU vs. INCOME TAX OFFICER, WARD-2(2)(1), KORAMANGALA

ITA 282/BANG/2026Status: DisposedITAT Bangalore31 August 2026AY 2019-202010 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer should have granted the assessee an opportunity to be heard before rejecting the immunity application. The matter was restored to the Assessing Officer to decide the immunity application afresh, considering the conditions for immunity and the delay in filing Form 68.

What were the facts?

The assessee failed to disclose certain receipts in its original return. A reassessment notice was issued, and the assessee filed a return declaring a lower income. Penalty proceedings were initiated for under-reporting of income, and the assessee sought immunity under Section 270AA, citing a delay in filing Form 68.

What were the issues?

Whether the assessee is eligible for immunity from penalty under Section 270AA despite a procedural delay in filing Form 68, and whether the Assessing Officer properly considered the assessee's explanation for under-reporting of income.

Which sections of the Income-tax Act were involved?

Section 270A,Section 270AA,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Respondent: Shri Venkatesh V, Addl. CIT DR

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

1.

Civil Technologies India Private Limited (the assessee/appellant) has filed this appeal against the order dated 27 November 2021 passed by the National Faceless Appeal Centre (NFAC), Delhi [the learned CIT(A)] for assessment year 2019-20. By that order, the NFAC confirmed the assessee’s appeal

ITA 282/BANG/2026 CIVIL TECH

The order continues below.

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