ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

ITA 3295/CHNY/2024Status: DisposedITAT Chennai06 June 2025AY 2018-19Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI JAGADISH (Accountant Member)51 pages
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What did the Tribunal hold?

The Tribunal held that the show cause notices issued for levying penalties were bad in law because they did not clearly specify the charges or faults against the assessees. This lack of specificity prejudiced the assessees' ability to defend themselves, violating principles of natural justice.

What were the facts?

The assessees, St. Joseph's Educational Trust and St. Joseph's Institute of Science & Technology Trust, appealed against penalties levied under Section 270A and Section 271AAB of the Income Tax Act. The core issue revolved around the validity of the show cause notices (SCNs) issued for these penalties.

What were the issues?

Whether the show cause notices issued for penalty levy were legally valid and sufficiently specific to allow the assessee to present a proper defense.

Which sections of the Income-tax Act were involved?

Section 270A,Section 271AAB,Section 274

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Cases cited in this judgment(13)Show list

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आयकर अपीलीय अिधकरण, ‘बी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक सद" एवं एवं एवं एवं "ी जगदीश, लेखा सद" के सम" BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT MEMBER

आयकर अपील सं./ITA Nos.3293 & 3294/Chny/2024 िनधा"रणवष"/Assessment Year: 2018-19 & 2020-21

v. St. Joseph’s Educational Trust, The DCIT, 56-C, Old Mahabalipuram Road, Central Circle-1(3), Sholinganallur, Chennai. Chennai-600 119. [PAN: AAMTS 3888 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

आयकर अपील सं./ITA Nos.3295 to 3297/Chny/2024 िनधा"रणवष"/Assessment Year: 2018-19 to 2020-21

v. St. Joseph’s Institute of Science & The DCIT, Technology Trust, Central Circle-1(3), 56-C, Old Mahabalipuram Road, Chennai. Sholinganallur, Chennai-600 119. [PAN: AAHTS 9943 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

अपीलाथ" क" ओर से/ Appellant by : Mr. V. Balaji, CA & Mr. K.R. Vasudevan, Advocate by Virtual ""यथ" क" ओर से /Respondent by : Ms. Anitha, Addl.CIT : सुनवाईक"तारीख/Date of Hearing 04.04.2025 : घोषणाक"तारीख /Date of Pronouncement 06.06.2025

ITA Nos.3293 & 3294/Chny/2024 (AYs 2018-19 & 2020-21) St. Joseph’s Educational Trust & ITA Nos.3295 to 3297/Chny

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