HARINAM,HARDOI vs. ITO-3(2), HARDOI, HARDOI
What did the Tribunal hold?
The Tribunal found that the assessee did not receive a reasonable opportunity during penalty proceedings and that the CIT(A) had summarily rejected explanations. Therefore, the matter was restored to the Assessing Officer for a de novo order.
What were the facts?
The assessee's appeals concerned penalties levied under Section 272A(1)(d) of the Income Tax Act. The assessee argued that penalties were imposed without a reasonable opportunity to be heard and that the corresponding quantum additions were also restored to the Assessing Officer.
What were the issues?
Whether penalties under Section 272A(1)(d) were rightly confirmed without providing a reasonable opportunity to the assessee and considering the defense of reasonable cause.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, LUCKNOW BENCH ‘A’, LUCKNOW
Before: SHRI KUL BHARAT, VICE- & ANADEE NATH MISSHRA
Heard together (3 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER ANADEE NATH MISSHRA:A.M.
(A) These appeals have been filed by the assessee against the impugned appellate order of learned CIT(A)/National Faceless Appeal Centre (NFAC), Delhi vide common order dated 13.01.2026 for the AY 2019-20 &2020-21 and dated 30.01.2026 for AY 2018-19 respectively. For the sake of convenie
The order continues below.
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More judgments on Section 272A(1)(d)
- Vipulbhai Keharbhai Kukadiya, Bhavnagar vs The Income Tax Office, Ward 1(9) Bhavnagar…ITA 2465/AHD/2026[2020-21]Status: Disposed16 Oct 2026AY 2020-21
- Vipulbhai Keharbhai Kukadiya, Bhavnagar vs The Income Tax Office, Ward 1(9) Bhavnagar…ITA 2464/AHD/2026[2020-21]Status: Disposed16 Oct 2026AY 2020-21
- Alkeshbhai Chimanbhai Barot, Ahmedabad vs ITO Ward 1(2)(1), AhmedabadITA 178/AHD/2026[2023-24]Status: Disposed13 Oct 2026AY 2023-24
- Alkeshbhai Chimanbhai Barot, Ahmedabad vs The ITO, Ward 1(2)(1), AhmedabadITA 177/AHD/2026[2017-18]Status: Disposed13 Oct 2026AY 2017-18
- Dineshkumar Chhaganlal Manavadaria, Junagadh vs ITO Ward 1, JunagadhITA 837/RJT/2025[2020-21]Status: Disposed9 Oct 2026AY 2020-21
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