INCOME TAX OFFICER, HOSUR vs. NARAYANASWAMY, HOSUR
आयकर अपीलीय अिधकरण, ’बी’ Ɋायपीठ, चेɄई
IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI
ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ एवं ŵी जगदीश, लेखा सद˟ के समƗ ।
Before Shri S.S. Viswanethra Ravi, Judicial Member &
Shri Jagadish, Accountant Member
आयकर अपील सं./I.T.A. No.822/Chny/2025
िनधाŊरण वषŊ/Assessment Year: 2018-19
D.No. 3/569, Subbagiri, Kamandoddi
Post, Hosur 635 130. [PAN:BHXPN8717L]
(अपीलाथŎ/Appellant)
(ŮȑथŎ/Respondent)
अपीलाथŎ की ओर से / Appellant by :
Ms. Gouthami Manivasagam, JCIT
ŮȑथŎ की ओर से/Respondent by :
Shri K. Prasanna, C.A.
सुनवाई की तारीख/ Date of hearing :
22.07.2025
घोषणा की तारीख /Date of Pronouncement
:
20.08.2025
आदेश /O R D E R
PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
This appeal filed by the Revenue is directed against the order dated
03.02.2025 passed by the ld. Commissioner of Income Tax (Appeals),
National Faceless Appeal Centre (NFAC), Delhi for the assessment year
2018-19. 2. The Appellant-Revenue raised 4 grounds of which, the only issue emanates for our consideration as to whether the ld. CIT(A) is justified in I.T.A. No.822/Chny/25
2
deleting the penalty levied under section 271D of the Income Tax Act,
1961 [“Act” in short] in the facts and circumstances of the case.
Brief facts relating to the case are that the assessee is an individual, sold immovable property and received sale consideration on his share of ₹.17,52,250/-. Since the assessee has not filed return of income for AY 2018-19, the Assessing Officer issued notice under section 148 of the Act. In response, the assessee filed return of income on 14.10.2022 declaring total income of ₹.2,42,850/-. Thereafter, the Assessing Officer issued statutory notices and the details are tabulated in page 2 of the assessment order. According to the Assessing Officer, as per the information available with Department, an unregistered sale agreement dated 29.04.2017 was executed between Sri Narayanaswamy (the assessee), Shri Annaiah Chinnaiah and Shri Sandeep Jalan for a sale consideration of immovable property for land of total area of 5 acres and 75 cents for ₹.3,47,87,500/-. The Assessing Officer also noted that the said land of total area of 6 acres and 79 cents was registered for a sale consideration of ₹.45,04,500/- vide document No. 2565/2017 on 22.09.2017 with the Sub-