VEDSIDDHA PRODUCTS PRIVATE LIMITED ,NAGPUR MAHARASHTRA vs. DCIT CENTRAL CIRCLE 2(1) NAGPUR, NAGPUR MAHARASHTRA

ITA 12/NAG/2026Status: DisposedITAT Nagpur31 August 2026AY 2016-175 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the penalty orders were passed beyond the period of limitation. The relevant date for calculating the limitation period was the date of initiation of penalty proceedings in the assessment order, not the date of issuance of the show cause notice.

What were the facts?

The assessee's appeals were against penalty orders passed under Section 271D of the Income Tax Act for assessment years 2016-17 to 2018-19. The primary contention was that the penalty orders were passed beyond the period of limitation prescribed by the Act.

What were the issues?

Whether the penalty orders under Section 271D were passed within the prescribed limitation period. The key issue was determining the correct starting point for calculating the limitation period.

Which sections of the Income-tax Act were involved?

Section 271D,Section 275(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, NAGPUR

Before: SHRI ANUBHAV SHARMA & SHRI KHETTRA MOHAN ROY

For Appellant: CA Sh. Swetanshu Dev, Adv
Hearing: 17.06.2026Pronounced: 31.08.2026

PER ANUBHAV SHARMA, JM:

These appeals preferred by the Assessee against the order of the Ld. Commissioner of Income Tax (A)-3, Nagpur (hereinafter referred to as the P a g e | 2 ITA Nos. 12 to 14/Nag/2026 Vedsiddha Products Pvt. Ltd. (AY: 2016-17 to 2018-19) First Appellate Authority or ‘the FAA’ for short) in appeals filed before him against the orders of the ld. Assessing Officer (hereinafter referred to as the L

The order continues below.

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