KARUR SREE RAMA TRADING PVT.LTD.,KARUR vs. ITO, CIRCLE-191), TRICHY

ITA 3841/CHNY/2025Status: DisposedITAT Chennai26 February 2026AY 2012-13Bench: me for the Assessment Year 2012-13, it appears to me that you have concealed the particulars of income” whereas, as per para 5 of the penalty order, the Assessing Officer concluded by holding that the assessee has furnished inaccurate particulars of its income. Thus, it is amply clear that the Assessing Officer has erred in not concluding the penalty order for which the notice has been issued under section 274 r.w.s. 271(1)(c) of the Act dated 26.12.2019. Further, as argued by the Id. AR, w1 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer erred in the penalty proceedings. The notice for penalty was issued for 'concealment of particulars of income,' but the penalty order was for 'inaccurate particulars.' Furthermore, the Assessing Officer did not record proper satisfaction for initiating penalty proceedings, and the reassessment order was made against a non-existent entity after the firm's conversion.

What were the facts?

The assessee, an erstwhile partnership firm that converted into a company, is appealing a penalty levied under section 271(1)(c) for assessment year 2012-13. The penalty was imposed based on a reassessment order.

What were the issues?

Whether the penalty levied under section 271(1)(c) is valid when the notice and penalty order differ, and the Assessing Officer failed to record proper satisfaction for initiating penalty proceedings.

Which sections of the Income-tax Act were involved?

Section 144,Section 147,Section 271(1)(c),Section 274

AI-generated summary — verify with the full judgment below

Before: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunatha

Hearing: 18.02.2026Pronounced: 26.02.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 30.10.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2012-13 passed under section 147/271(1)(c) of the Income Tax Act, 1961 [“Act” in short].

2.

At the outset, the ld. AR Shri Y. Sridhar, F.C.A. submits that the ld. CIT(A) er

The order continues below.

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