DCIT,CIRCLE-1,RANCHI, RANCHI vs. CENTRAL COALFIELDS LIMITED, RANCHI

ITA 220/RAN/2024Status: DisposedITAT Ranchi20 February 2026AY 2012-13Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)24 pages
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What did the Tribunal hold?

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal set aside the penalty order.

What were the facts?

The Assessing Officer (AO) initiated penalty proceedings under Section 271(1)(c) after making additions/disallowances in the assessment order. The AO imposed a penalty of 150% of the tax sought to be evaded. The Commissioner of Income Tax (Appeals) partly allowed the appeal by reducing the penalty to 100%.

What were the issues?

Whether a penalty imposed under Section 271(1)(c) is valid when the notice issued under Section 274 is defective for not specifying the limb of the section under which penalty is levied.

Which sections of the Income-tax Act were involved?

Section 271(1)(c),Section 274

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Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri M.K. Chowdhary &, Shri Devesh Poddar, A.Rs
For Respondent: Shri Rajib Jain, CIT-DR
Hearing: 05/01/2026Pronounced: 20/02/2026

PER: BENCH

1.

The appeal filed by the assessee and the cross appeal filed by the revenue are directed against the order of the National Faceless Appeal Centre (NFAC), Delhi/learned Commissioner of Income Tax (Appeals), [in short, the ld. CIT(A)] dated 15/03/2024 for the Assessment Year (AY) 2012-13. The assessee in its appeal has raised following grounds of appeal:

"

1.

For that the impugned order passed against order u/s 271(1)(c) is unjustified, uncalled for on facts

The order continues below.

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