ITAT Indore Judgments — August 2025

The Tribunal held that the assessee had a reasonable cause for non-compliance with the notices, as contemplated under Section 273B of the Income-tax Act, 1961. The Tribunal found strong merit in the assessee's submissions. Firstly, the notices were issued during the Covid-19 pandemic, a period of exceptional difficulty, and the short compliance period of 4-5 days was unreasonable. The Tribunal noted the Supreme Court's suo motu order extending limitations from 15.03.2020 onwards due to the pandemic. Secondly, the Tribunal acknowledged the force in the argument that the AO did not supply the required documents, making it impossible for the assessee to comply. Even if an email was sent, the dates mentioned (13.03.2020 and 17.03.2020) were around the period when the Supreme Court granted extensions. Relying on the principle laid down in Hindustan Steel Ltd. Vs. State of Orissa (1972) 83 ITR 26 (SC), which states that penalty should not be imposed for a technical or venial breach or where the breach flows from a bona fide belief, the Tribunal decided to delete the penalties. The assessee succeeded in all appeals.

The Tribunal held that the assessee had a reasonable cause for non-compliance with the notices, as contemplated under Section 273B of the Income-tax Act, 1961. The Tribunal found strong merit in the assessee's submissions. Firstly, the notices were issued during the Covid-19 pandemic, a period of exceptional difficulty, and the short compliance period of 4-5 days was unreasonable. The Tribunal noted the Supreme Court's suo motu order extending limitations from 15.03.2020 onwards due to the pandemic. Secondly, the Tribunal acknowledged the force in the argument that the AO did not supply the required documents, making it impossible for the assessee to comply. Even if an email was sent, the dates mentioned (13.03.2020 and 17.03.2020) were around the period when the Supreme Court granted extensions. Relying on the principle laid down in Hindustan Steel Ltd. Vs. State of Orissa (1972) 83 ITR 26 (SC), which states that penalty should not be imposed for a technical or venial breach or where the breach flows from a bona fide belief, the Tribunal decided to delete the penalties. The assessee succeeded in all appeals.

The Tribunal held that the assessee had a reasonable cause for non-compliance with the notices, as contemplated under Section 273B of the Income-tax Act, 1961. The Tribunal found strong merit in the assessee's submissions. Firstly, the notices were issued during the Covid-19 pandemic, a period of exceptional difficulty, and the short compliance period of 4-5 days was unreasonable. The Tribunal noted the Supreme Court's suo motu order extending limitations from 15.03.2020 onwards due to the pandemic. Secondly, the Tribunal acknowledged the force in the argument that the AO did not supply the required documents, making it impossible for the assessee to comply. Even if an email was sent, the dates mentioned (13.03.2020 and 17.03.2020) were around the period when the Supreme Court granted extensions. Relying on the principle laid down in Hindustan Steel Ltd. Vs. State of Orissa (1972) 83 ITR 26 (SC), which states that penalty should not be imposed for a technical or venial breach or where the breach flows from a bona fide belief, the Tribunal decided to delete the penalties. The assessee succeeded in all appeals.

The Tribunal held that the assessee had a reasonable cause for non-compliance with the notices, as contemplated under Section 273B of the Income-tax Act, 1961. The Tribunal found strong merit in the assessee's submissions. Firstly, the notices were issued during the Covid-19 pandemic, a period of exceptional difficulty, and the short compliance period of 4-5 days was unreasonable. The Tribunal noted the Supreme Court's suo motu order extending limitations from 15.03.2020 onwards due to the pandemic. Secondly, the Tribunal acknowledged the force in the argument that the AO did not supply the required documents, making it impossible for the assessee to comply. Even if an email was sent, the dates mentioned (13.03.2020 and 17.03.2020) were around the period when the Supreme Court granted extensions. Relying on the principle laid down in Hindustan Steel Ltd. Vs. State of Orissa (1972) 83 ITR 26 (SC), which states that penalty should not be imposed for a technical or venial breach or where the breach flows from a bona fide belief, the Tribunal decided to delete the penalties. The assessee succeeded in all appeals.

The Tribunal held that the assessee had a reasonable cause for non-compliance with the notices, as contemplated under Section 273B of the Income-tax Act, 1961. The Tribunal found strong merit in the assessee's submissions. Firstly, the notices were issued during the Covid-19 pandemic, a period of exceptional difficulty, and the short compliance period of 4-5 days was unreasonable. The Tribunal noted the Supreme Court's suo motu order extending limitations from 15.03.2020 onwards due to the pandemic. Secondly, the Tribunal acknowledged the force in the argument that the AO did not supply the required documents, making it impossible for the assessee to comply. Even if an email was sent, the dates mentioned (13.03.2020 and 17.03.2020) were around the period when the Supreme Court granted extensions. Relying on the principle laid down in Hindustan Steel Ltd. Vs. State of Orissa (1972) 83 ITR 26 (SC), which states that penalty should not be imposed for a technical or venial breach or where the breach flows from a bona fide belief, the Tribunal decided to delete the penalties. The assessee succeeded in all appeals.