KHATEEB OMAIR AHMED,CHENNAI vs. ITO, NCC-4(1), CHENNAI

ITA 3092/CHNY/2025Status: DisposedITAT Chennai19 June 2026AY 2004-058 pages
AI SummaryAllowed

What were the facts?

The assessee's income was assessed and penalties were levied. The assessee appealed against the penalty orders, primarily on grounds of jurisdiction and limitation.

What did the Tribunal hold?

The Tribunal held that the penalty orders were time-barred as they were passed beyond the prescribed limitation period under Section 275 of the Income Tax Act. The TOLA Act 2020 could not be leveraged by the Revenue in this case.

What were the issues?

The key issues were whether the penalty proceedings were initiated and completed within the time limits prescribed by Section 275 of the Income Tax Act, and whether the faceless assessment unit had the jurisdiction to conduct penalty proceedings.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 275(1)(a),Section 275(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HONOURABLE SHRI ABY T. VARKEY & SHRI GAGAN GOYAL

Hearing: 11.06.2026Pronounced: 19.06.2026

PER GAGAN GOYAL, AM: These two appeals preferred by the assessee against the order of Ld. Commissioner of Income Tax (A) / NFAC, (hereinafter referred as the ‘Ld. CIT(A)’) dated 11.09.2025, for the Assessment Years (hereinafter referred as the ‘AYs’) 2004-05 & 2011-12. ITA – 3092, AY – 2004-05

GROUNDS OF APPEAL

1.

The order passed by the Respondent is erroneous in law and opposed

The order continues below.

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