262 ITR 260 (Delhi) and Commissioner of Income Tax-VI v. Worldwide Townships Project Ltd.

367 ITR 433High Court2014#8438 most cited

What is 262 ITR 260 (Delhi) and Commissioner of Income Tax-VI v. Worldwide Townships Project Ltd. authority for?

Transactions settled by journal entry, without actual cash movement, do not violate Section 269SS or Section 269T, and consequently, penalties under Section 271D or Section 271E are not leviable.

13

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2014 to 2025.

Also referred to as

CIT vs Worldwide Townships Project Ltd · 262 ITR 260 · 367 ITR 433 · section 269SS · section 271D · section 269T · section 271E · journal entry · cash payment · penalty

Sections most often in play

Section 269SSSection 271DSection 132(1)Section 143(3)Section 153ASection 153CSection 269STSection 269T

Issues it is cited on

section 269tsection 271esection 269sssection 271dsection 269section 273blevy of penaltysection 26section 27section 271reasonable causeprescribed

Judgments citing 262 ITR 260 (Delhi) and Commissioner of Income Tax-VI v. Worldwide Townships Project Ltd.

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Seven Seas Hospitality Private Limited, New Delhi

ITA 2226/DEL/2025[2019-20]Status: DisposedITAT Delhi14 Nov 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Anil Jain, CA &For Respondent: Shri Amit Jain, CIT-DR
Section 153ASection 269SSection 271DSection 274Section 275(1)(c)Section 27I

…absence of any law or proposition being cited to the contrary. The ground no. 5 of the Revenue challenges the impugned order on basis of failure of ld.CIT(A) to ignore decision of Hon’ble Delhi High Court in CIT Vs. Worldwide Township Projects Limited (2014) 367 ITR 433 (Del), but the question there was with regard to limitation period for initiation of penalty proceedings and not the need for recording reasons in the assessment order for initiation of penalty proceedings. Thus grounds have no substance. The discussion applies to both the appeals in hand and same are dismissed. Order pronounced in the open court…

Assistant Commissioner of Income Tax, CC-30, New Delhi vs. Seven Seas Hospitality Private Limited, New Delhi

ITA 2225/DEL/2025[2018-19]Status: DisposedITAT Delhi14 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Anil Jain, CA &For Respondent: Shri Amit Jain, CIT-DR
Section 153ASection 269SSection 271DSection 274Section 275(1)(c)Section 27I

…absence of any law or proposition being cited to the contrary. The ground no. 5 of the Revenue challenges the impugned order on basis of failure of ld.CIT(A) to ignore decision of Hon’ble Delhi High Court in CIT Vs. Worldwide Township Projects Limited (2014) 367 ITR 433 (Del), but the question there was with regard to limitation period for initiation of penalty proceedings and not the need for recording reasons in the assessment order for initiation of penalty proceedings. Thus grounds have no substance. The discussion applies to both the appeals in hand and same are dismissed. Order pronounced in the open court…

Modesty Garments, New Delhi vs. JCIT, Range-28(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2574/DEL/2022[2016-17]Status: DisposedITAT Delhi03 Jan 2025AY 2016-17

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us[Assessment Year : 2016-17] Modesty Garments Vs Jcit B-304, New Friends Colony Range-28(1) New Delhi-110025. New Delhi Pan-Aaafm1598F Appellant Respondent Appellant By Shri Mohit Gupta, Ca Shri Nitin Sharma, Ca & Shri Neeraj Singh, Ca Respondent By Shri Anshul, Sr. Dr Date Of Hearing 07.10.2024 Date Of Pronouncement 03.01.2025

Section 250Section 269T

…69T of the Act and consequently penalty under s. 271E would not be attracted. 6.2. The Hon’ble Delhi High Court in the case of CIT vs Noida Toll Bridge Co. Ltd. (2003) 262 ITR 260 (Del) order dated 28.01.2003; CIT-VI vs Worldwide Township Projects Ltd. (2014) 367 ITR 433 (Del), have held that when no payment is made in cash but the same is effected by journal entry in the books of accounts of the assessee, there is no violation of s. 269SS or s.269T so as to warrant imposition of penalty under s. 271D or s. 271E of the Act. Similar view has been taken in CIT vs Govind Kumar (2002) 253 ITR 103 (Rajasthan). 7. Unde…

Otm Jewellery Private Limited, Delhi vs. ACIT, Central Range, Meerut

In the result, the appeal of the assessee in ITA No

ITA 1135/DEL/2024[2013-14]Status: DisposedITAT Delhi23 Oct 2024AY 2013-14

Bench: Shri Kul Bharat & Shri Naveen Chandra

For Appellant: Shri Ankur Goel, AdvFor Respondent: Ms. Anupama Singla, Sr. DR
Section 132(1)Section 153CSection 269SSection 271DSection 273B

…cause under section 273B. The ld AR relied upon a catena of decisions as under: i) CIT Vs. Apex Finlease Ltd dated 17,.10.2016 Hon'ble Allahabad High Court ii) CIT Vs. National Clothing Co. 2014 SCC Online Del 7253 iii) CIT Vs. Worldwide Township Projects 367 ITR 433 iv) CIT Vs. Saurabh Enterprises 269 CTR 451(Allahabad) v) CIT Vs. Noida Toll Bridge Co. 262 ITR 260 vi) DCIT Vs. International Softweb 2016 SCC ITAT 1901 vii) ACIT Vs. Vardhan Fashion 60 TAxmann.com 407 viii) ACIT Vs. Ruchika Chemicals and Investment ITA No, 1466/DEL/1997 dated 18.04.2022 ix) ITO Vs. Amar Nath Shivrah HUF 1 SOT 346 [Agra] x…

DCIT-15(3)(1), Mumbai vs. M/S. Translands Infrastructure Developers P Ltd, Vashi

In the result, the appeal of the revenue is dismissed

ITA 1913/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Sept 2023AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailthe Dy. Commissioner Of Vs. M/S Translands Income-Tax, 15(3)(1), Infrastructure Developers Mumbai P. Ltd. Jn-3-14-5, Asshirwad Chs, Sector-09, Vashi, Navi Mumbai-400 703 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadct 0036 B Appellant .. Respondent

For Appellant: Ms. Rupa NandaFor Respondent: Shri P. D. Chougule, Sr. AR
Section 143(3)Section 147Section 269SSection 271DSection 273BSection 3Section 68

…present case also the Hon'ble TIAT has deleted the addition made by AO u/s.68 of Act of Rs.1,85,00,000/- Thus, the said transaction is held as genuine and not made to evade tax. f) The Hon'ble Delhi High Court in CIT vs World Wide Township Projects Limited in 367 ITR 433 held as under- "A plain reading of the section 269SS indicates that it applies to a transaction where a deposit or a loan is accepted by an assessee, otherwise than by an account payee cheque or an account payee draft. The ambit of the section is clearly restricted to transaction involving acceptance of money and not intended to affect cases wher…

Ram Singh, Karnal vs. Addi. CIT Range, Karnal

In the result, the appeal is allowed

ITA 1457/DEL/2020[2010-11]Status: DisposedITAT Delhi11 Aug 2022AY 2010-11

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2010-11

Section 139(1)Section 147Section 148Section 269SSection 271DSection 273BSection 4

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND DR. B.R.R. KUMAR, ACCOUNTANT MEMBER Assessment Year: 2010-11 Sh. Ram Singh, Vs. Addl. CIT, H. No. 1550, Sector-7, Range Karnal Urban Estate, Karnal, Haryana PAN :AZQPS7536M (Appellant) (Respondent) Appellant by Dr. Rakesh Gupta, Advocate Sh. Somil Agarwal, Advocate Respondent by Ms. Indu Sen, Sr. DR Date of hearing 30.06.2022 Date of pronouncement 11.08.2022 ORDER PER SAKTIJIT DEY, JM: Captioned appeal has been filed by the assessee challenging the order dated 13.03.2020 passed by learned Commissio…

Raman Chaudhary, Karnal vs. Addi. CIT Spl. Range, Karnal

In the result, the appeal is allowed

ITA 1456/DEL/2020[2010-11]Status: DisposedITAT Delhi11 Aug 2022AY 2010-11

Bench: Shri Saktijit Dey & Dr. B.R.R. Kumarassessment Year: 2010-11

Section 139(1)Section 147Section 148Section 269SSection 271DSection 273B

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘F’ NEW DELHI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND DR. B.R.R. KUMAR, ACCOUNTANT MEMBER Assessment Year: 2010-11 Sh. Raman Chaudhary, Vs. ACIT, H. No. 1550, Sector-7, Special Range, Urban Estate, Karnal, Karnal Haryana PAN :AFOPC1631G (Appellant) (Respondent) Appellant by Dr. Rakesh Gupta, Advocate Sh. Somil Agarwal, Advocate Respondent by Ms. Indu Sen, Sr. DR Date of hearing 30.06.2022 Date of pronouncement 11.08.2022 ORDER PER SAKTIJIT DEY, JM: Captioned appeal has been filed by the assessee challenging the order dated 13.03.2020 passed by learned…

Shri Sanjaykumar Haribhai Patel, Ahmedabad vs. Addl. CIT, Range-4(1), Ahmedabad

In the result the appeal of the assessee is allowed for the statistical purposes

ITA 1762/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad25 Oct 2021AY 2014-15

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 1762/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 Sanjaykumar Haribhai Patel, A.C.I.T, 401, Shubham Complex, Vs. Range-4(1), Opp. Navrangpura, Ahmedabad. Ahmedabad-380009. Pan: Alqpp3785L

For Appellant: Shri S.N. Divetta, A.RFor Respondent: Shri Vinod Tanwani, CIT.D.R
Section 250Section 269TSection 271ESection 271tSection 273B

…e doubted. Accordingly, there cannot be any penalty under the provisions of section 271E in pursuance to the provisions of section 273B of the Act. 9.2 Likewise, the Hon’ble Delhi High Court in the case of CIT vs. Worldwide Township Projects Ltd. reported in 367 ITR 433 has held as under: A plain reading of the section 269SS indicates that it applies to a transaction where a deposit or a loan is accepted by an assessee, otherwise than by an account payee cheque or an account payee draft. The ambit of the section is clearly restricted to transaction involving acceptance of money and not intended to affect cases…

Pr.Commissioner of Income Tax-6 vs. Nirman Overseas Pvt Ltd

ITA/618/2016HC Delhi22 Aug 2016

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MS. JUSTICE DEEPA SHARMA

Section 269TSection 271E

…two stages. This was sought to be treated as violative of Section 269T. The ITAT affirmed the CIT (A)’s decision firstly by referring to the Division Bench’s decision of this Court in Commissioner of Income Tax. v. Worldwide Township Projects Ltd. (2014) 367 ITR 433 (Delhi) and observed as follows:- “6. We have perused the orders passed by the authorities below and the paper book filed before us. It is observed that the ld. AO has not disputed the transactions, and has not observed any part of the amount to be unexplained money. It has nowhere been recorded in the penalty order that the transactio…

DCIT, New Delhi vs. M/S Nirman Overseas Pvt. Ltd., New Delhi

In the result, the appeal filed by the Revenue stands dismissed

ITA 3952/DEL/2013[2006-07]Status: DisposedITAT Delhi09 Mar 2016AY 2006-07

Bench: Shri J.S. Reddy & Smt. Beena A. Pillai

Section 143(3)Section 269TSection 271E

…se and the explanations provided by the assessee, penalty u/s 271E cannot be imposed. 10. Before us the ld. AR placed his reliance upon the decision of the Hon’ble Jurisdictional High Court in the case of CIT vs. World Wide Township Projects Ltd. reported in 367 ITR 433(2014). The Hon’ble Jurisdictional High Court has observed as under: “The ambit of the Section is clearly restricted to transaction involving acceptance of money and not intended to affect cases where a debt or a liability I.T.A. No. 3952/D/2013 arises on account of book entries. The object of the Section is to prevent transactions in currency…

Nav- Yug Sewing Machine Co. Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 5471/DEL/2012[2007-08]Status: DisposedITAT Delhi22 Sept 2015AY 2007-08

Bench: : Shri I.C. Sudhir & Shri L.P. Sahu

For Appellant: Shri Surjeet Singh, C.AFor Respondent: Shri P. Dam Kanunjna, Sr. DR
Section 143(3)Section 269SSection 271Section 271DSection 273B

…later on adjusted against share capital and shares were issued subsequently. In support, ld. AR of the assessee relied upon following decisions: (i). CIT vs. Noida Toll Bridge Co. Ltd., 262 ITR 260 (Del) (ii). CIT vs. Worldwide Township Projects Ltd. (2014) 367 ITR 433 (Delhi) (iii). Order dated 16.01.2015 of ITAT, Delhi (ITA Nos.2253 & 2259/Del/2013 & Ors.) in the cases of ACIT vs. M/s. Vardaan Fashion and ACIT vs. Shri Inderpal Singh Wadhawan. (iv). Bombay Conductors & Electricals Ltd. vs. DCIT(1996) 56 TTJ(Ahd.) 580 (v). Sunflower Builders (P) Ltd. vs. DCIT (1996) 61 ITD (Pune) 227. (vi). Order dt. 21.01.11…

Commissioner of Income Tax vs. M/S National Clothing Co

ITA - 221 / 2003HC Delhi12 Dec 2014
Section 260ASection 269SSection 271D

…rcials and Investment Pvt. Ltd. This decision follows two earlier decisions of this Court in Commissioner of Income Tax vs. Noida Toll Bridge Co. Ltd. [2003] 262 ITR 260 (Delhi) and Commissioner of Income Tax-VI vs. Worldwide Townships Project Ltd. [2014] 367 ITR 433 (Delhi). In the said decisions, in view of the language of Explanation to Section 269SS, it has been held that the provision would apply to loan or deposit of money, and not mere formal entries resulting in debit or credit. Other reasons and grounds have been elucidated. 6. In view of the aforesaid legal position, the question of law ha…

Commissioner of Income Tax vs. M/S National Clothing Co

ITA/221/2003HC Delhi12 Dec 2014
Section 260ASection 269SSection 271D

…rcials and Investment Pvt. Ltd. This decision follows two earlier decisions of this Court in Commissioner of Income Tax vs. Noida Toll Bridge Co. Ltd. [2003] 262 ITR 260 (Delhi) and Commissioner of Income Tax-VI vs. Worldwide Townships Project Ltd. [2014] 367 ITR 433 (Delhi). In the said decisions, in view of the language of Explanation to Section 269SS, it has been held that the provision would apply to loan or deposit of money, and not mere formal entries resulting in debit or credit. Other reasons and grounds have been elucidated. 6. In view of the aforesaid legal position, the question of law ha…