ROHIT ENTERPRISES,INDORE vs. CIT(APPEALS)-3,BHOPAL, BHOPAL

ITA 917/IND/2025Status: DisposedITAT Indore08 May 2026AY 2022-2311 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that a penalty under Section 272A(1)(d) cannot be sustained if the assessment is completed on merits under Section 143(3) without drawing adverse inferences for non-compliance. The Tribunal also noted that the facts were identical to other group concerns where similar penalties were deleted.

What were the facts?

The Assessing Officer imposed penalties on the assessees for alleged failure to comply with notices issued under Section 142(1) during scrutiny assessments. However, the assessments were ultimately completed under Section 143(3) after considering the assessees' submissions.

What were the issues?

Whether penalties for non-compliance with notices are sustainable when the assessment is completed on merits, and whether the imposition of penalty is justified if the non-compliance was not willful or contumacious.

Which sections of the Income-tax Act were involved?

Section 142(1),Section 143(3),Section 144,Section 272A(1)(d)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI B.M. BIYANI & SHRI PARESH M. JOSHI

For Appellant: Shri Prabhpreet Sheetal, AR
For Respondent: Shri Ashish Porwal, Sr. DR
Hearing: 29.04.2026Pronounced: 08.05.2026

Per

The order continues below.

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