DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

ITA 1899/CHNY/2025Status: DisposedITAT Chennai30 October 2025AY 2021-2237 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the penalty was wrongly levied as the assessee provided confirmations from a significant number of depositors, and the remaining ones also denied making deposits. The Ld. CIT(A) had rightly deleted the penalty based on the AO's own remand report acknowledging the genuineness of the denials.

What were the facts?

During a search, the Revenue found data suggesting the assessee received cash fixed deposits of Rs. 43.20 crore from 153 persons. Many of these persons denied making such deposits. The Assessing Officer initiated penalty proceedings under Section 271D for violating Section 269SS.

What were the issues?

Whether the penalty levied under Section 271D for violation of Section 269SS was justified when the assessee provided evidence denying the cash deposits, and whether the penalty proceedings were initiated within the prescribed limitation period.

Which sections of the Income-tax Act were involved?

Section 269SS,Section 271D,Section 275

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Income Tax Appellate Tribunal, C BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI S.R.RAGHUNATHA

PER ABY T. VARKEY, JM: This appeal has been preferred by the Revenue and Cross Objection filed by the assessee is against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred to as `Ld.CIT(A)`), Chennai- 19, dated 07-04-2025 for the Assessment Year (hereinafter referred to as `AY`) 2021-22. 2. At the outset

The order continues below.

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