SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, CENTRAL RANGE-4,, NEW DELHI

ITA 2926/DEL/2025Status: DisposedITAT Delhi09 January 2026AY 2018-19Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the penalty orders were barred by limitation as per Section 275(1)(c) of the Income-tax Act. The period of limitation is to be counted from the date the Assessing Officer made a reference for penalty imposition, not from the date of the subsequent show-cause notice.

What were the facts?

The assessee's appeals concerned penalties imposed under Sections 271D and 271E. The assessment orders were completed on December 29, 2022, with penalty proceedings initiated thereafter. However, the penalty orders were passed on January 30, 2024, leading to a dispute over limitation.

What were the issues?

The primary issue was whether the penalty orders were passed within the time limit prescribed under Section 275(1)(c) of the Income-tax Act, considering when penalty proceedings were initiated.

Which sections of the Income-tax Act were involved?

Section 271D,Section 271E,Section 275(1)(c)

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Income Tax Appellate Tribunal, DELHI BENCHES ‘C’: NEW DELHI.

Before: SHRI S.RIFAUR RAHMAN & SHRI VIMAL KUMAR

For Appellant: Shri Rajeshwar Prasad Painuly, CA
For Respondent: Shri Dayainder Singh Sidhu, CIT DR
Hearing: 04.11.2025

Heard together (4 matters)

ITA No.2920/Del/2025
ITA No.2922/Del/2025
ITA No.2924/Del/2025
ITA No.2926/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The assessee has filed appeals against the order of the Learned Commissioner of Income Tax (Appeals)-26, New Delhi [“Ld. CIT(A)”, for short] dated 15.03.2025, for the Assessment Years 2015-16 and 2018-19 affirming the penalty orders passed u/s 271D and 271E of the Income-tax Act, 1961 (for short ‘the Act’).

2.

Since the issues are common and the appeals are connected, hence the same are heard together and being disposed off by this commo

The order continues below.

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