VIJAYAWADA TOLLWAY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-8(1), HYDERABAD

ITA 1468/HYD/2025Status: DisposedITAT Hyderabad06 February 2026AY 2012-1310 pages
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What did the Tribunal hold?

The Tribunal held that the AO failed to record specific satisfaction regarding concealment of income or furnishing of inaccurate particulars in the assessment order. This lack of mandatory satisfaction renders the penalty proceedings invalid.

What were the facts?

The Assessing Officer (AO) reopened the assessee's assessment and made a significant disallowance of expenditure, leading to an addition to income. Subsequently, the AO initiated penalty proceedings under Section 271(1)(c) of the Income Tax Act.

What were the issues?

Whether penalty proceedings under Section 271(1)(c) are validly initiated without the Assessing Officer recording specific satisfaction in the assessment order regarding concealment or inaccurate particulars of income.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 143(3),Section 147

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, Hyderabad ‘ A‘Bench, Hyderabad

Before: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri A.V. Raghuram, Advocate
Hearing: 17/12/2025

Per Madhusudan Sawdia, A.M.: This appeal is filed by M/s. Vijayawada Tollway Private Limited (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 21.07.2025 for the A.Y. 2012-13. 2. appeal: The assessee has raised the following grounds of “1. That the orders passed by the Assessing Officer and CIT(A) is bad in law, contrary to facts of the ca

The order continues below.

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