RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

ITA 1836/BANG/2025Status: DisposedITAT Bangalore22 January 2026AY 2014-15Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that penalty under Section 270A cannot be invoked when the assessed income matches the returned income, as there is no under-reporting. Furthermore, offering income on an estimated basis without specific findings of misreporting does not attract penalty under Section 270A(9)(e).

What were the facts?

Following a search, the assessee voluntarily offered additional income at 1% of turnover to cover potential discrepancies. The Assessing Officer accepted this additional income but initiated penalty proceedings under Section 271(1)(c) (later referred to as Section 270A). The CIT(A) confirmed the penalty.

What were the issues?

Whether penalty under Section 270A is leviable when assessed income equals returned income and when income is offered on an estimated basis without specific findings of misreporting.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 270A

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Cases cited in this judgment(6)Show list

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Income Tax Appellate Tribunal, ‘B’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri V Srinivasan, Advocate
For Respondent: Shri Subramanian, JCIT
Hearing: 13.01.2026Pronounced: 22.01.2026

PER BENCH:

These 6 appeals, filed by the assessee against the separate order of the learned Commissioner of Income Tax (Appeal) (hereafter- learned CIT(A)) under the provision of section 250 of the Income Tax Act, 1961 (hereafter- the Act), were heard together.

First, we take up ITA No. 1835/Bang/2025 pertaining to AY 2013-14

ITA No.1835 to 1840/Bang/2025 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity are not inclined to reproduce here.

3.

The grounds of appeal filed by the assessee are interconnected and pertain

The order continues below.

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