M/S CENTRAL COALFIELDS LTD.,,RANCHI vs. ACIT/DCIT, CIRCLE-1, RANCHI

ITA 383/RAN/2025Status: DisposedITAT Ranchi11 June 202610 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that penalty under Section 270A of the Act cannot be confirmed without a specific finding on whether the penalty was for under-reporting or misreporting of income. The Tribunal deleted the penalty imposed by the Assessing Officer.

What were the facts?

The assessee company faced penalty proceedings under Section 270A of the Income Tax Act for alleged under-reporting and misreporting of income. The Assessing Officer initiated penalty proceedings, and the CIT(A) confirmed the penalty. The assessee appealed against the penalty.

What were the issues?

Whether penalty under Section 270A is valid if the specific limb (under-reporting or misreporting) is not specified. Whether the penalty order is sustainable without recording satisfaction on the exact limb of Section 270A.

Which sections of the Income-tax Act were involved?

Section 270A,Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri M.K. Chowdhary and Shri Devesh
For Respondent: Shri Ashish Kumar Daharia, CIT-DR
Hearing: 24/04/2026Pronounced: 11/06/2026

PER: BENCH

1.

ITA No. 370/Ran/2025 and ITA No. 383/Ran/2025 are the appeals filed by the assessee and ITA No. 387/Ran/2025 is the appeal filed by the revenue. The appeals are directed against the separate orders of the National Faceless Appeal Centre (NFAC) Delhi [in short, the ld. CIT(A)] dated, 22/08/2025, 25/08/2025 and 29/09/2025 for the Assessment Years (AY) 2018-19 to 2020-

The order continues below.

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