THE FEROZEPUR CENTRAL CO OPERATIVE BANK,FEROZEPUR vs. DCIT CIRCLE III, FEROZEPUR

ITA 1029/ASR/2026Status: DisposedITAT Amritsar30 September 2026AY 2012-20135 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the expenditure was genuine and only a timing difference in claiming the deduction, there was no furnishing of inaccurate particulars of income. It was considered a judgmental error or a genuine mistake.

What were the facts?

The assessee, a cooperative bank, claimed a deduction for interest on borrowed funds in AY 2012-13. The AO disallowed this as the expenditure pertained to AY 2011-12, and a penalty was levied under Section 271(1)(c).

What were the issues?

Whether a genuine claim of expenditure in the wrong assessment year constitutes furnishing inaccurate particulars of income warranting penalty.

Which sections of the Income-tax Act were involved?

Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: SHRI SAKTIJIT DEY, HON’BLE & SHRI GIRISH AGRAWAL, HON’BLE

For Appellant: Shri Vinamar Gupta, CA
For Respondent: Shri Prashant Singh, Sr. DR (Virtual)

PER: SHRI SAKTIJIT DEY, V.P.:

Today the stay application, in S.A. No. 15/Asr/2026, listed before the Division Bench. In course of hearing, the parties agreed for disposal of the appeal itself. Accordingly, the Registry was directed to list the appeal along with present stay application.

The present appeal arises out of the order dated 30th June, 2026, of National Faceless

2.

Appeal Centre (NFAC), Delhi, pertaining to the assessment year 2012-13, confirming the 2 Asst. Year: 2012-13 penalty imposed under Section 271(1)(c) of the Income Tax Act, 1961 [in short “the Act”] alleging furnishing of inaccurate particulars of income.

3

The order continues below.

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