AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

ITA 1121/AHD/2025Status: DisposedITAT Ahmedabad16 January 2026AY 2011-12Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)14 pages
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What did the Tribunal hold?

The Tribunal held that the assessee had made a plausible claim based on accounting standards and judicial precedents, and had disclosed the change in accounting policy. Therefore, the penalty was not leviable as there was no deliberate concealment or furnishing of inaccurate particulars.

What were the facts?

The assessee bank claimed deduction for lease operating expenses based on a change in accounting policy, which was disallowed by the Assessing Officer. Subsequently, penalty proceedings were initiated under Section 271(1)(c) for furnishing inaccurate particulars of income.

What were the issues?

Whether penalty under Section 271(1)(c) is leviable when the assessee claims deduction based on a change in accounting policy and judicial precedents, and whether the penalty order was passed within the time limit.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 275

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Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: MS. SUCHITRA RAGHUNATH KAMBLE & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Tushar Hemani, Sr. Advocate & Shri Kushal
For Respondent: Shri Sher Singh, CIT. DR
Hearing: 08.01.2026Pronounced: 16.01.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

These five appeals are filed by the assessee against separate orders of National Faceless Appeal Centre(NFAC), Delhi [hereinafter referred to as ‘CIT(A)’], all dated 06.03.2025 for the Assessment Years (A.Y.) 2011-12 to 2015-16 respectively, in the proceedings u/s 271(1)(c) of the Income Tax Act.

2.

As the facts involved in the five appeals were common and the grounds raised by the assessee were also identical, all the matters were heard together and are being dispo

The order continues below.

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