S V COMPLEXES LLP,HYDERABAD vs. DCIT, CENTRAL CIRCLE-3(2), HYDERABAD, HYDERABAD

ITA 1309/HYD/2026Status: DisposedITAT Hyderabad24 June 2026AY 2023-2476 pages
AI SummaryAllowed

What were the facts?

During a search operation, incriminating materials including tally data were seized, indicating alleged cash receipts from customers in violation of Section 269ST. The assessee admitted additional income to cover discrepancies.

What did the Tribunal hold?

The Tribunal held that the Assessing Officer had not conclusively proved the violation of Section 269ST to levy penalty under Section 271DA. The penalty was considered unsustainable due to discrepancies in seized data and the assessee having paid taxes on admitted income.

What were the issues?

Whether penalty under Section 271DA can be levied without conclusively proving violations of Section 269ST, and if admitted income and tax payment provide immunity from such penalties.

Which sections of the Income-tax Act were involved?

Section 271DA,Section 269ST,Section 132,Section 143(3),Section 147,Section 115BFA(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

For Appellant: Dr. Narendra Kumar Naik, CIT-DR and Dr. Sachin Kumar, Sr. A.R

PER BENCH : The captioned appeals filed by the assessee firm i.e. “S V Complexes LLP” are directed against the separate, but identical orders of the learned Commissioner of Income Tax (Appeals), Hyderabad – 11, [for

The order continues below.

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