M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

आदेश / O R D E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of

the Learned Commissioner of Income Tax (Appeals), (hereinafter in short

‘the Ld.CIT(A)’), Chennai-18, dated 07.08.2025, for the Assessment Year

(hereinafter in short ‘AY’) 2008-09 to 2010-11 confirming the penalty-

imposed u/s.271(1)(c) of the Income Tax Act, 1961 (hereinafter referred

to as ‘the Act‘).

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the penalty appeal for AY 2008-09 is taken as the lead case, and the

result of which will be followed for other years/appeals. The main

grievance of the assessee is against the action of the Ld.CIT(A)

confirming the penalty. The assessee is noted to have raised issues on

merits including legal issues and the Ld AR drew our attention to the

grounds/additional grounds of appeal filed before this Tribunal; and he

wants us to examine a legal issue wherein challenge is made to the

notices issued by the AO u/s.274 r.w.s.271(1)(c) of the Act dated

31.03.2015 [for AYs 2008-09 to AY 2010-11] as bad in law being

defective/invalid in law and therefore, according to assessee, the penalty

imposed needs to be quashed.

order for the Assessment Year 2008-09, are that the appellant-assessee,

is a public limited company, which is engaged in the business of letting its

properties in industrial park. And it filed its return of income for the

Assessment year 2008-09 on 30.09.2008 admitting income of

Rs.14,09,720/-, which was selected for scrutiny and an order u/s 143(3)

of the Act, dated 18.11.2010 was passed in this case. Later, a search was

conducted in the premises of the MD of the assessee company on

11.10.2012 and certain material relating to the assessee were found and

seized. Consequently, the assessment was completed vide order dated

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31.03.2015 u/s 153C r.w.s. 153A by, inter-alia, treating the rental

receipts offered under 'business income' as 'income from house property'

and thereby disallowing exemption claimed u/s 10A of Rs.90,37,808/-.

Consequently, penalty proceedings u/s 271(1)(c) were also initiated by

the AO. The quantum assessment was taken up in first appeal by the

assessee and the issue of treating rental income from IT Park as business

income and consequently the claim of exemption u/s 10A was allowed in

favour of the Assessee by the Ld CIT(A)- 18, Chennai by order dt

27.09.2017. The Revenue filed appeal before this Tribunal, on the issue of

claim of exemption u/s 10A of the Act. And the Tribunal vide its order

[ITA No.271/Chny/2018 dt:30.07.2019] allowed the appeal of Revenue

with respect to exemption u/s 10A, and dismissed the Cross objection

[(CO) No 45/Chny/2018] filed by the Assessee. Later, the Assessee has

filed appeal before Hon'ble Madras High Court, which was admitted on

20.12.2019, against the Tribunal order and is pending. Meanwhile, the AO

for the relevant assessment year issued penalty notice u/s.271(1)(c) of

the Act on 31.03.2015, which later concluded on 24.03.2020 by the AO

passing the order imposing penalty on the ground that the assessee had

furnished inaccurate particulars of income with regard to the deduction of

Rs.90,37,808/-claimed u/s 10A of the Act and thereby levied penalty u/s

271(1)(c) amounting to Rs.30,71,950/-being 100% of the tax sought to

be evaded. Aggrieved, assessee is noted to have filed appeal before Ld

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CIT(A), who by passing the impugned order has confirmed the penalty.

Aggrieved, the assessee-company is before this Tribunal.

raised the legal issue of AO issuing defective notice, we will deal with it

first. The Ld.AR drew our attention to the impugned notice issued by the

AO, and pointed out that the AO has not struck down the limbs/faults

which are not applicable in the facts of the assessee’s case for levy of

penalty. In other words, the AO erred in imposing penalty u/s.271(1)(c)

of the Act, without specifically mentioning in the impugned notice u/s.274

r.w.s. 271(1)(c) of the Act, what specific fault/infraction assessee should

defend against the proposed penalty 271(1)(c) i.e. whether the assessee

furnished inaccurate particulars of his income, or concealed the

particulars of his income, without which the impugned notice is bad in law

for being vague/arbitrary and not issued without application of mind. In

order to buttress his arguments, he has cited the case-law/decision of the

Hon’ble jurisdictional Madras High Court in the case of Babuji Jacob

reported in 430 ITR 259 (Madras), wherein, in on an identical case,

penalty was levied by the AO u/s.271(1)(c) of the Act; and the assessee

challenged the imposition of penalty, inter alia, on the ground that the

notice issued by AO u/s.271(1)(c) of the Act, in the printed form without

specifically mentioning whether the proposed penalty was initiated for

concealment of particulars of income or on account of furnishing of

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inaccurate particulars of income, was bad in law; and the Hon’ble Madras

High Court answered the question in favor of assessee and held that such

an omission/failure on the part of AO, to specify the fault in the notice is

legally untenable and such notice is defective and invalid. Therefore, Ld

AR, urged that since AO had issued the impugned notice for captioned

assessment years [AYs] without striking down the inapplicable portion in

the printed notice, the same was issued without due application of mind

and suffers for being vague; and due to omission on the part of AO to

spell out clearly the infraction for which assessee was called upon to

explain/defend, the assessee didn’t know what was the charge/fault, the

AO had in mind, to levy penalty u/s 271(1)(c) of the Act, therefore the

impugned notice is bad in law and therefore the penalty levied needs to

be deleted. The Ld.AR also relied on the following case laws:

assailed the plea of the Ld.AR of the assessee for cancelling penalty levied

u/s.271(1)(c) of the Act on the ground that the notice issued u/s.274

r.w.s.271(1)(c) of the Act was defective and invalid for the failure on the

part of the AO not striking down the limbs/fault for levying penalty.

According to the Ld.DR, the plea of the assessee is erroneous since the

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Hon’ble Supreme Court in the case of Gangotri Textiles Ltd. v. DCIT

reported in [2022] 137 taxmann.com 198 (SC), has confirmed the action

of the Hon’ble Madras High Court repelling similar grounds raised by the

assessee that notice issued before penalty was levied u/s.271(1)(c) of the

Act was invalid since the notice issued by the AO [u/s.274 r.w.s.271(1)(c)

of the Act] had reflected both the two (2) limbs of Clause (c) of Section

271(1) of the Act. Further, according to the Ld.DR, since the decision of

the Hon’ble Supreme Court in the case of Gangotri Textiles Ltd. (supra)

has been rendered in the year 2022, it nullifies the following other

decisions cited by the assessee before this Tribunal:

the case of Sundaram Finance Ltd. v. DCIT reported in [2018] 403 ITR

107 (Madras) wherein, the assessee had raised similar grounds (defective

notice) was dismissed. And therefore, she wants us to reject the legal

issue raised by the assessee and the grounds of appeal decided on merits

and doesn’t want us to interfere with the order of the Ld.CIT(A).

submission of Ld DR for Revenue, submitted that the decision of the

Hon’ble Supreme Court in the case of Gangotri Textiles Ltd. was decided

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by the Hon’ble Madras High Court by order dated 25.08.2020 in favour of

the Revenue and the SLP preferred by the assessee has been dismissed

by the Hon’ble Supreme Court, refusing to exercise its powers under

Article 136 of the Constitution and thus, according to him, dismissal of the

SLP was an action without going into the merits of the decision of the

Hon’ble Madras High Court. Therefore, the Ld AR asserted that dismissal

of SLP in limine by passing a non-speaking order without indicating any

reasons for its dismissal implies that the Supreme Court has decided not

to exercise its discretion to hear the appeal filed before it. For such a

proposition, he relied on the decision of the Hon’ble Supreme Court in the

case of Kunhayammed v. State of Kerala reported in [2000] 6 SCC 359

(SC), wherein the Hon’ble Supreme Court has observed as under:

"A petition for leave to appeal to this Court may be dismissed by a non- speaking order or by a speaking order. Whatever be the phraseology employed in the order of dismissal, if it is a non-speaking order, i.e. it does not assign reasons for dismissing the special leave petition, it would neither attract the doctrine of merger so as to stand substituted in place of the order put in issue before it nor would it be a declaration of law by the Supreme Court under Article 141 of the Constitution for there is no law which has been declared.

...iv) An order refusing special leave to appeal may be a non-speaking order or a speaking one. In either case it does not attract the doctrine of merger. An order refusing special leave to appeal does not stand substituted in place of the order under challenge. All that it means is that the Court was not inclined to exercise its discretion so as to allow the appeal being filed."

Court refusing Special Leave Petition to appeal doesn’t attract the

doctrine of merger and doesn’t substitute in place of the order under

challenge the order of the Hon’ble Supreme Court in order to be the

ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 8 ::

declaration of Law by the Hon’ble Supreme Court under Article 141 of the

Constitution. Therefore, according to the Ld.AR, the dismissal of SLP in

the case of Gangotri Textiles Ltd., can’t be said to have nullified the

following other decisions cited in the impugned order of the Tribunal:

Ltd. (supra), was clearly distinguishable as discussed infra and therefore,

the decision cannot be said to have judicial precedence to the case in

hand. He pointed out that the Hon’ble Madras High Court in Gangotri

Textiles Ltd. (supra) has clearly found in the facts of that case the

assessee therein had understood the contents/ faults spelt out in the

notices issued u/s.274 r.w.s.271(1)(c) of the Act and observed that there

was indeed concealment of the particulars of income/furnishing of

inaccurate particulars of income. Moreover, in that case, the Hon’ble High

Court noted that the legal ground assailing the defect in the notice was

raised for the first time before it and therefore, declined to entertain the

same by holding that such a ground doesn’t raise a substantial question

of law. Therefore, the Gangotri Textiles (supra) was distinguishable on

the facts and therefore, the ratio laid down by the Hon’ble Madras High

Court in the case of Gangotri Textiles Ltd. is not applicable to the facts of

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the present assessee. Moreover, the Ld.AR drew our attention to the fact

that the order in the case of Gangotri Textiles Ltd. (supra) in favour of the

Revenue was passed on 25.08.2020 whereas the decision in the case of

Babuji Jacob v. ITO reported in [2021] 430 ITR 259 (Mad.)(HC) was

passed after 08.12.2020 and by the very same Judge, Hon’ble Justice T.S.

Shivagnanam, who had taken note of the decision in the case of

Sundaram Finance Ltd v. ACIT reported in [2018] 403 ITR 407 which was

challenged by Sundaram Finance before the Hon’ble Supreme Court by

filing SLP which was dismissed and reported in [2018] 99 taxmann.com

152 (SC). Having considered all the contentions of the Revenue and after

considering a host of decision, their Lordships was pleased to hold in the

case of Babuji Jacob (supra) that the notice initiating penalty proceedings

if found to be defective and invalid, imposition of penalty vitiated/un-

warranted. Therefore, according to the Ld.AR, the legal issue raised

regarding defective notice u/s.271(1)(c) of the Act needs to be allowed

and penalty cancelled.

on record. Since the assessee has raised, inter-alia, legal issue regarding

invalid notice issued u/s.271(1)(c) r.w.s.274 of the Act, we will

examine/adjudicate the said legal issue. For doing that, first of all we

have to peruse the show cause notice (SCN) issued by the AO u/s

271(1)(c) r.w.s. 274 of the Act dated 31.03.2015 by which the AO gave

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notice to the assessee as to “why an order imposing a penalty on you

should not be imposed u/s 271(1)(c) of the Act?” On perusal of the SCN

dated 31.03.2015 [for all the captioned AYs], we note that both the faults

specified in Section 271(1)(c) of the Act are given therein i.e. “have

concealed the particulars of his income” or “furnished inaccurate

particulars of such income”. In other words, the AO has put to notice the

assessee on both the faults without striking down the inapplicable fault

which could have specified which fault AO has in mind that assessee has

committed i.e. whether he is proposing penalty for the fault of

“concealment of particulars of income” or “for furnishing of inaccurate

particulars of income”. We note that by not striking down one of fault, the

assessee was not in a position to defend properly the charge/fault against

which the AO was proposing to levy penalty because both faults are

different and distinct. Therefore, the notice was per-se confusing and

vague; and infirm in eyes of law, for non-application of mind of the AO

before issuing notice u/s.274 r.w.s.271(1)(1)(c) of the Act, as well as

exposes the whimsical/arbitrary attitude of the AO, who has scant regard

for Rule of Law and therefore, bad in law; and such notice cannot be held

to be valid and legally tenable as pleaded by Revenue; and we note that

in similar factual background, this Tribunal has consistently held such

notices to be bad in law for not specifying the specific fault for which the

assessee was being proceeded against for levy of penalty. And such

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actions of the Tribunal has been upheld by several judgments of the

various High Courts. In this regard, we note that in a similar case, where

there was difference of opinion by two Division Benches, the Full Bench of

the Hon’ble Bombay High Court in the case of Mohd. Farhan A. Shaikh Vs.

DCIT (2021) 434 ITR 1 (Bombay) dated 11.03.2021 held that the show

cause notice issued prior to levy of penalty without specifying the

fault/charge against which the assessee is being proceeded, would vitiate

the penalty itself. And thus the Hon’ble High Court upheld the view of the

division bench order in the case of PCIT Vs. Goa Dourado Promotions (P.)

Ltd. (Tax Appeal No.18 of 2019, dated 26.11.2019) and held that the

contrary view taken by the other Division Bench in the case of CIT Vs.

Smt. Kaushalya (1995) 216 ITR 660 (Bom) does not lay down the correct

proposition of law.

31.03.2015 didn’t explicitly convey to the assessee the specific

fault/charge the assessee was being proceeded against for levy of

penalty. Resultantly, the show cause notice is found to be

defective/invalid, and therefore it is held to be bad in law. For doing that

we also rely on the decision of the Hon’ble Karnataka High Court in the

case of CIT vs Manjunatha Cotton and Ginning Factory reported in (2013)

359 ITR 565 (Kar) and further notes that the Department’s SLP against it

has been dismissed by the Hon’ble Supreme Court. We also find that

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Hon’ble Karnataka High Court in the case of CIT Vs. SSA’s Emerald

Meadows, reported in (2016) 73 taxmann.com 241 (Kar) endorsed the

same view in Manjunatha Cotton and Ginning Factory (supra) and held as

under:-

“3. The Tribunal has allowed the appeal filed by the assessee holding the notice issued by the Assessing Officer under section 274 read with Section 271(1)(c) of the Income Tax Act, 1961 (for short ‘the Act’), to be bad in law as it did not specify which limb of Section 271(1)(c) of the Act, the penalty proceedings had been initiated i.e., whether for concealment of particulars of income or furnishing of inaccurate particulars of income. The Tribunal, while allowing the appeal of the assessee, has relied on the decision of the Division Bench of this Court rendered in the case of CIT Vs. Manjunatha Cotton & Ginning Factory (2013) 359 ITR 565/218 Taxman 423/35 taxmann.com 250(Kar). 4. In our view, since the matter is covered by judgment of the Division Bench of this Court, we are of the opinion, no substantial question of law arises in this appeal for determination by this Court. The appeal is accordingly dismissed.”

deal with similar question in the case of Babuji Jacob (supra) wherein, the

Hon’ble High Court (DB) had framed substantial question of law, inter-

alia, as under:

“i. Whether the notice issued under Section 271(1)(c) of the Act dated 30.3.2016 in the printed form without specifically mentioning whether the proceedings are initiated on the ground of concealment of income or on account of furnishing of inaccurate particulars is valid and legal ?

ii. Whether the proceedings initiated by the respondent/the Assessing Officer is legal and valid?

iii. Whether the Appellate Tribunal is justified otherwise in rejecting the said technical ground of wrong initiation of the penalty proceedings under Section 271(1)(c) of the Act in misreading the show cause notice dated 30.3.2016 proving perversity in the findings of facts at para 6.5 of the impugned http://www.judis.nic.in order? “

show cause notice in that case as under:-

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case of Sundaram Finance Ltd., which was also cited by the Ld.DR before

us and observed in this regard as under:

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And thereafter, the Hon’ble Madras High Court held that the notice

initiating penalty proceedings was defective and invalid and allowed the

appeal of the assessee and answered the question of law in favour of the

assessee.

u/s.274 r.w.s 271(1)(c) by the AO dated 31.03.2015 were infirm/invalid

in the eyes of law for all the captioned AYs. Therefore, in light of the

aforesaid decision of the Hon’ble Madras High Court in the case of Babuji

Jacob (supra), and other case laws discussed, we direct the deletion of

the penalty levied in all the three captioned appeals. And since the

penalty notice issued by AO itself are invalid & legally untenable,

consequent penalty levied for concealment of particulars of income are

null in eyes of law. Therefore, assessee succeeds and the penalty levied

is directed to be deleted.

Ld.AR for Revenue against the legal issue, we allowed supra. The main

contention of the Revenue is that the case laws cited by the Ld.AR of the

assessee, especially in the case of Babuji Jacob (supra) and other cases

are nullified in the light of the decision of the Hon’ble Supreme Court in

the case of Gangotri Textiles Ltd. (supra). According to the Revenue,

similar legal issue [defective notice] was raised by that assessee i.e.

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Gangotri Textiles Ltd., initially before the Hon’ble Madras High Court,

which contention/issue was repelled by the Hon’ble High Court and

thereby the Hon’ble High Court was pleased to pass an order in favour of

the Revenue by order dated 25.08.2020. And such a decision was

challenged by the assessee before the Hon’ble Supreme Court by filing

SLP which was dismissed on 18.02.2022 by the Hon’ble Supreme Court

which order reads as under:

We have heard Shri Arvind P. Datar, learned senior counsel appearing on behalf of the petitioner. In the facts and circumstances of the case, we do not want to interfere with the impugned judgment and order passed by the High Court in exercise of powers under Article 136 of the Constitution of India. Hence, the Special Leave petitions stand dismissed. Pending application(s) shall stand disposed of. 18. According to the Revenue, since the Hon’ble Supreme Court upheld

the action of the Hon’ble Madras High Court in the case of Gangotri

Textiles Ltd. (supra), similar legal issue raised by the assessee in respect

of defective notice should be answered against the assessee. Further

according to the Revenue, since the SLP has been dismissed in 2022, all

other orders cited by the Tribunal in the impugned order stands nullified.

We don’t agree with the contention of the Revenue. Doctrine of merger

doesn’t take place when the Hon’ble Supreme Court refuses Special Leave

to appeal. In other words, the order of the Hon’ble High Court [under

challenge before the Hon’ble Supreme Court] doesn’t get substituted by

ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 16 ::

the order of the Hon’ble Supreme Court. This position of law has been

clarified by the Hon’ble Supreme Court itself that SLP dismissal or refusal

by the Hon’ble Supreme Court to entertain Special Leave to appeal before

it, doesn’t mean that the order challenged before it, gets substituted by

the order of the Supreme Court and in such an event the doctrine of

merger doesn’t take place. In other words, the order challenged before

the Hon’ble Supreme Court [in the case of Gangotri Textiles supra, by the

Hon’ble Madras High Court] doesn’t merge with the decision of the

Hon’ble Supreme Court and therefore, it can’t be held to be a declaration

of law by the Hon’ble Supreme Court under Article 141 of the

Constitution. For such a proposition, we rely on the following decisions:

I. Kunhayammed v. State of Kerala (2000)6 SCC 359 II. Khoday Distilleries v. Sri Mahadeshwara Sahakara Sakkare Karkhane (2019) 2 SCC 136 19. Having said so, we also find force in the submission of the Ld.DR

that the order passed by the Hon’ble Madras High Court in the case of

Gangotri Textiles Ltd., was on the peculiar facts of that case and so, it is

distinguishable. And in that case, the defect in the notice was raised for

the first time before the Hon’ble Madras High Court, which was also a

fact, the Hon’ble High Court noted to refuse admission of the same; and

secondly, the Hon’ble High Court took note of the distinguishing facts of

the case, wherein the assessee didn’t disclose about the sale of its land &

ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 17 ::

windmill in its RoI filed u/s.139(1) of the Act on 26.09.2012 and after ‘13’

months of issuance of statutory notice u/s.143(2) of the Act, the assessee

by letter dated 03.03.2015, admitted that due to oversight, it didn’t offer

the capital gains in its return and attached a summary of total income

adjusting profit on the LTCG & STCG; and even at that stage, didn’t

bother to file revised return. Considering the aforesaid facts, the Hon’ble

High Court wondered as to how the assessee while responding to the

penalty notice dated 12.03.2015, could have asserted that there was no

concealment of income or furnishing of inaccurate particulars of income as

envisaged, sec.271(1)(c) of the Act. The Hon’ble High Court took note of

the fact that, the assessee didn’t disclose about the sale of the land &

windmill in its return which fact/omission was clearly discernable from the

perusal of the RoI/ITR, wherein, at the relevant column, it is stated as

‘nil’. In such factual back ground, the Hon’ble High Court held that “it will

not only be a case of filing of inaccurate particulars, but also a case of

concealment of income” meaning in the peculiar facts both faults are

attracted. Therefore, in the aforesaid factual back ground, the assessee

having understood the ingredients of the penalty proposed to be levied

against it, coupled with the omission on the part of the assessee of not

raising the invalidity/legal issue pertaining to the notice before the

Ld.CIT(A)/Tribunal, refused to entertain the legal issue regarding defect in

the notice and was of the view that there was no substantial question of

ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 18 ::

law against the action of the Tribunal confirming the penalty

u/s.271(1)(c) of the Act. Therefore, the decision rendered in Gangotri

Textiles Ltd.supra, is distinguishable on the peculiar facts of that case and

therefore, dismissal of the SLP refusing leave to appeal, as noted supra

would not come to the aid of the Revenue to wipe out the stare-

decisis/judicial precedent of ratio laid down by the Hon’ble jurisdictional

High Court in the case of Babuji Jacob (supra). Therefore, we don’t find

any merits in the submissions/written submissions by the Revenue

against the legal issue of defective notice dated 31.03.2015 for all AYs

before us and which has been decided on the binding ratio of decision of

the Hon’ble jurisdictional High Court in the case of Babuji Jacob (supra)

and other case laws cited supra; and hence, we don’t find any merit in the

submissions of the Ld.DR for Revenue and hence rejected.

Order pronounced on the 18th day of February, 2026, in Chennai.

Sd/- Sd/- (प�ावती .एस) (एबी टी. वक�) (PADMAVATHY. S) (ABY T. VARKEY) लेखा सद�य/ACCOUNTANT MEMBER �याियक सद�य/JUDICIAL MEMBER चे�ई/Chennai, �दनांक/Dated: 18th February, 2026. TLN

ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 19 :: आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF