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“penalty under section 270A”

PenaltySection 270ASection 270A523 judgments

The decision most relied on for penalty under section 270A is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on penalty under section 270A

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Vinay Cements Ltd.
213 CTR 268 · 2007 · Supreme Court
422
citing judgments

Employees' contributions to provident fund and ESI are allowable as a deduction under Section 36(1)(va) read with Section 2(24)(x) if deposited by the assessee before the due date for filing the income tax return.

CIT v. Virgo Marketing (P) Ltd.
171 Taxmann 156 · 2008 · High Court
384
citing judgments

The assessment order must clearly specify the reason for initiating penalty proceedings under Section 271(1)(c) and explicitly state whether it is for concealment of income or furnishing inaccurate particulars. Failure to identify the specific limb under which penalty is initiated renders the penalty unsustainable.

CIT v. Zoom Communication (P) Ltd.
327 ITR 510 · 2010 · High Court
330
citing judgments

Penalty under section 271(1)(c) is not leviable for legally unsustainable claims if the assessee provides a substantiated, bona fide explanation without concealing facts or giving incorrect information. However, penalty is attracted if a claim is baseless, legally incorrect, and the explanation lacks bona fides.

Judgments citing penalty under section 270A

Bhikhabhai Somabhai Patel, Sabarkantha vs. The ITO, Ward-1, Himatnagar

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 2596/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19
For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Rajkumar M Vasavda, Sr. DR
Section 144Section 270ASection 57

hereinafter referred to as the “Act”), the other appeal lies against order of the Ld. CIT(A) confirming the levy of penalty under Section 270A of the Act on the addition made to the income of the assessee in the quantum proceedings. 2. Issues involved in both the appeals being

Ashutosh Dubey, Kanjurmarg vs. DCIT Circle-8, Pune

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

ITA 2215/PUN/2025[2019-20]Status: DisposedITAT Pune18 Feb 2026AY 2019-20

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2215/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Ashutosh Dubey, V Income Tax Officer, Tower 8, Flat No.3201, Runwal S Circle-8, Pune. Forest, Lbs Road, Kanjurmarg West, Maharashtra – 400078 Pan: Ajppd0173M Appellant/ Assessee Respondent /Revenue Assessee By Shri Amar Pandey (Virtual) Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 20/01/2026 Date Of Pronouncement 18/02/2026

Section 139Section 139(1)Section 147Section 148Section 246ASection 250Section 270ASection 274(2)Section 5

addition. Hence, there is no under reporting. Ld.AR further submitted that on identical facts, 4 ITA No.1286/PUN/2025 [A] Assessing Officer had dropped penalty under section 270A for A.Y.2018-19 in assessee’s own case. Ld.AR filed copy of the said order. Ld.AR therefore submitted that penalty may be dropped. 6. Ld.AR ... income voluntarily under section 139(1) of the Act. Therefore, there is under reporting of income, hence, AO was right in levying penalty under section 270A of the Act. 8. In this case, admittedly Assessee had not filed Return of Income u/s.139(1) of the Act. Assessee filed Return

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2616/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

deleted. 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 270A of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well as the merits of the case. Your Appellant

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2615/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

deleted. 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 270A of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well as the merits of the case. Your Appellant

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2614/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

deleted. 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 270A of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well as the merits of the case. Your Appellant

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2613/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

deleted. 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 270A of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well as the merits of the case. Your Appellant

Gujarat Medical Education and Research Society Ahmedabad, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeals of the assessee for A

ITA 2612/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 10Section 234ASection 270ASection 271(1)(c)Section 271ASection 69

deleted. 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 270A of the Act merely relying on the order passed by the learned Assessing Officer, without independently verifying the facts as well as the merits of the case. Your Appellant

Rns Power Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Ward-5(1)(1), Bengaluru

In the result appeal filed by the assessee is allowed

ITA 1421/BANG/2025[2020-21]Status: DisposedITAT Bangalore17 Feb 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Prasanna Urala, AdvocateFor Respondent: Shri Subramanian, Jt.CIT(DR)(ITAT), Bengaluru
Section 115JSection 119Section 139Section 143Section 270ASection 80

year was dismissed. Therefore assessee is in appeal before us. The solitary ground of appeal is with respect to the confirmation of the penalty under section 270A of the Act of Rs.2 22,26,572 levied by the income tax department. 2. The brief facts of the case shows that

Mansukhlal Mohanlal Mehta HUF, Mumbai vs. Income Tax Officer Ward 41(2)(3), Mumbai

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

ITA 5049/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokars.A. No. 173/Mum/2025 (Assessment Year: 2018-19) Mansukhlal Mohanlal Ito Ward-41(2)(3), Mehta Huf Kautilya Bhavan, B-102, Krishakunj, S. N. Vs. Bandra Kurla Road, Mulund West, Complex, Mumbai- Mumbai-400 080 400 051 Pan/Gir No. Aaghm5909Q (Applicant) (Respondent) Assessee By Ms. Kalpana Gandhi, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 10.02.2026 Date Of Pronouncement 13.02.2026

Section 143(3)Section 144BSection 154Section 250Section 270Section 270ASection 56(2)(x)

quantum appeal is presently pending before the learned CIT(A). 12. We have considered the rival submissions and perused the record. The penalty under section 270A is directly linked to addition made under section 56(2)(x) in the assessment order dated 26.04.2021. It is not disputed that the quantum

Unilever India Exports Limited, Mumbai vs. Deputy Commissioner of Income-Tax Central Circle - 5(2), Mumbai

In the result, both the appeals of the assessee for Assessment Years 2015–16 and 2016–17 are allowed

ITA 4157/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar & Unilever India Dcit Central Exports Limited, Circle-5(2), Unilever House, B. D. Vs. Room No. 427, 4Th Sawant Marg, Floor, Kautilya Chakala, Andheri Bhawan, C-41 To C- East, Sahar P & T 43, G Block, Bandra Colony, S. O. Kurla Complex, Mumbai-400 099 Bandra (East), Mumbai- 400 051. Pan/Gir No. Aaaci0991D (Applicant) (Respondent) Assessee By Ms. Karishma Phatarphekara/W Shri Harsh Shah & Shri Shreyas Sardesai, Ld. Ars Revenue By Shri Pankaj Kumar, Ld. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 12.02.2026

Section 143(3)Section 144C(13)Section 144C(5)Section 254

case and in law, the learned AO has erred in levying interest under section 234B and section 234D of the Act. Initiation of penalty under section 270A: 9. Whether on the facts and in the circumstances of the case and in law, the learned AO has erred in initiating penalty ... erred in computing the interest under section 234A and 234B of the Act while computing the Appellant's total liability? Initiation of penalty under section 270A: 10. Whether on the facts and in the circumstances of the case and in law, the learned AO has erred in initiating penalty proceedings

Unilever India Exports Limited, Mumbai vs. Deputy Commissioner of Income-Tax Central Circle - 5(2), Mumbai

In the result, both the appeals of the assessee for

ITA 4156/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

Section 143(3)Section 144C(13)Section 144C(5)Section 254

case and in law, the learned AO has erred in levying interest under section 234B and section 234D of the Act. Initiation of penalty under section 270A: 9. Whether on the facts and in the circumstances of the case and in law, the learned AO has erred in initiating penalty ... erred in computing the interest under section 234A and 234B of the Act while computing the Appellant's total liability? Initiation of penalty under section 270A: 10. Whether on the facts and in the circumstances of the case and in law, the learned AO has erred in initiating penalty proceedings

Tncp LLP., Coimbatore vs. ITO, Ncw-1(1), Coimbatore

ITA 2603/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Feb 2026AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:2602 & 2603/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Tncd Llp, 126, Kg House, Arts College Road, Coimbatore - 641 018. [Pan:Aagft-8799-R] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Ito, Vs. Non Corporate Ward -1(1), Coimbatore. (प्रत्यर्थी/Respondent) : Shri. N. Arjun Raj, Advocate : Ms. R. Anitha, Addl.C.I.Τ. सुनवाई की तारीख/Date Of Hearing घोषण की तारीख/Date Of Pronouncement Per S. R. Raghunatha, Am: आदेश /Order : 20.11.2025 : 11.02.2026 These Appeals Of The Assessee Are Filed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘Ld.Cit(A)') For The Assessment Year 2018-19, Both Dated 09.07.2025 Against The Assessment Orders Passed By The Ao, Nfac, Delhi, U/S.143 (3) R.W.S 144B Of The Income Tax Act, 1961 (In Short ‘The Act') Dated 20.09.2021 & The Penalty Order Passed By The Ao, Nfac, Delhi, U/S.270A Of The Act Dated 15.01.2022 Respectively. :-2-:

Section 142(1)Section 143Section 143(2)Section 23Section 23(1)Section 24Section 270ASection 36(1)(va)

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Shell International Petroleum Company Limited, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )-4(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 1751/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Feb 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalshell International Petroleum Vs Deputy Commissioner Of Company Limited Income Tax (International C/O B S R & Co. Llp, 2Nd Floor, Taxation) 4(2)(1), Lodhaexcelus, Apollo Mills Mumbai Compound, N.M. Joshi Marg, Mahalakshmi, Mumbai 400011

For Appellant: Shri Madhur Agarwal and Shreyas Sardesai, AdvocatesFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 144C(5)Section 2(24)Section 234BSection 9(1)(vi)

issued to the Appellant wherein no refund was received by the Appellant without appreciating the facts and circumstance of the case. Penalty under section 270A of the Act 14. Erred in levying penalty under section 270A of the Act for underreporting of income without appreciating the facts and circumstances

Uday Uttamrao Nevase, Pune vs. The Assessing Officer / Assessment Unit, Pune

In the result, appeal of the assessee in ITA No

ITA 2606/PUN/2025[2022-23]Status: DisposedITAT Pune10 Feb 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2606/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Uday Uttamrao Nevase, V The Assessing Officer / Saugandh Niwas, Hind Colony S Assessment Unit, Pune. Lane No.1 A, Bhekrai Nagar, Phursungi, Pune – 412308. Pan: Akqpn1150Q Appellant/ Assessee Respondent /Revenue Assessee By Ca Rohan Gupta Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 16/12/2025 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 04.09.2025 Emanating From The Penalty Order Passed Under Section 270A, Dated 17.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “Ground 1 Section 270Aa Immunity Cit A Erred In Law By Confirming The Penalty Of Rs 629382 Under Section 270A Without Considering And

Section 143(3)Section 250Section 270A

filed any appeal against these additions. It means, Assessee has accepted the additions. 7. In the assessment order, Assessing Officer has also initiated penalty under section 270A of the Act. Assessing Officer after providing opportunity of hearing, levied penalty. The relevant part of the penalty order is as under ... from imposition of penalty, etc. 270AA. (1) An assessee may make an application to the Assessing Officer to grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C or section 276CC, if he fulfils the following conditions, namely:— (a) the tax and interest payable

M/S. Citadines Omr Aparthotel Private Limited, Chennai vs. ITO Corp Ward 1(3), Chennai

In the result, the appeal of the assessee is allowed and the stay application of the assessee is dismissed as infructuous

ITA 303/CHNY/2026[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.303/Chny/2026 & Sa No.29/Chny/2026 (Arising Out Of Ita No.303/Chny/2026) िनधा$रण वष$ /Assessment Year: 2018-19 M/S. Citadines Omr Aparthotel Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-1(3), No.94, Somerset Greenways, Chennai. Sathyadev Avenue, Raja Annamalaipuram, Chennai – 600 028. Pan: Aadcr 5653C

For Respondent: Ms. R. Anitha, Addl. CIT
Section 143(3)Section 250Section 263Section 270ASection 270A(6)(a)Section 40A(7)

Immunity from imposition of penalty, etc.—(1) An assessee may make an application to the Assessing Officer to grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C of section 276CC, if he fulfils the following conditions, namely:— (a) the tax and interest payable

ACIT, Delhi vs. Manik Wadhwa, Uttar Pradesh

ITA 4349/DEL/2025[2020]Status: DisposedITAT Delhi05 Feb 2026

Bench: Shri Mahavir Singh, Hon'Ble & Smt. Renu Jauhri, Hon'Ble

Section 119Section 270A

4349_DEL_2025_Manik Wadhwa IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SHRI MAHAVIR SINGH

Raghu Rama Renewable Energy Limited, Hyderabad vs. ITO., Ward-3(1), Hyderabad

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

ITA 876/HYD/2025[2018-19]Status: DisposedITAT Hyderabad04 Feb 2026AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 145(2)Section 250

under Section 270A of the Income-tax Act, 1961 dated 27.03.2022, levying penalty for under-reporting of income. 14. The A.O. levied penalty under Section 270A of the Act, in respect of additions made by the A.O. towards disallowance of interest expenses under Section ... which is 50% of the amount of tax sought to be evaded. 15. The assessee challenged the order passed by the A.O. imposing penalty under Section 270A of the Act before the Ld. CIT(A). The Ld. CIT(A), vide order dated 22.04.2025, has partly allowed the appeal filed

Raghu Rama Renewable Energy Limited, Hyderabad vs. ITO., Ward-3(1), Hyderabad

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

ITA 875/HYD/2025[2018-19]Status: DisposedITAT Hyderabad04 Feb 2026AY 2018-19
Section 145(2)Section 250

under Section 270A of the Income-tax Act, 1961 dated 27.03.2022, levying penalty for under-reporting of income. 14. The A.O. levied penalty under Section 270A of the Act, in respect of additions made by the A.O. towards disallowance of interest expenses under Section ... which is 50% of the amount of tax sought to be evaded. 15. The assessee challenged the order passed by the A.O. imposing penalty under Section 270A of the Act before the Ld. CIT(A). The Ld. CIT(A), vide order dated 22.04.2025, has partly allowed the appeal filed

M/S Eklavya Estate Pvt.Ltd., Ranchi vs. Deputy Commissioner of Income Tax, Central Circle-2, Ranchi

In the result, this appeal of the assessee is allowed

ITA 258/RAN/2024[2018-19]Status: DisposedITAT Ranchi03 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Eklavya Estate Pvt. Ltd., D.C.I.T., H-95, Harmu Housing Colony, Central Circle-2, Vs. Ranchi-834002 (Jharkhand) Ranchi. Pan No. Aabce 5815 F Appellant/ Assessee Respondent/ Revenue

Section 133ASection 270ASection 274

appeal against the quantum addition is still pending before the ld. CIT(A). However, in the mean time, the Assessing Officer imposed penalty under Section 270A of the Act. The ld. CIT(A) vide the impugned order, confirmed the penalty imposed under Section 270A of the Act on the ground ... under which limb of provisions of section 270A(2) or 2704(9) the case of the assessee falls, then in that case, no penalty under section 270A is leviable. Therefore, the order of the Commissioner (Appeals) is to be upheld (Para 7.6) Even otherwise also, it is an admitted fact

Hasmukh Hiralal Shah, Mumbai vs. ITO 22(1)(6), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 7532/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Feb 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarhasmukh Hiralal Shah National Faceless 9/13, Nehru Nagar, Opp. Appeal Centre Bdd Chawl No. 9, Worli Vs. /Ito-22(1)(6), Mumbai-400 018 Room No. 206, Piramal Chambers, Parel, Mumbai – 400 012 Pan/Gir No. Aavps2340A (Applicant) (Respondent) Assessee By Shri Vimal Punmiya, Ld. Ar Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 03.02.2026

Section 143(3)Section 249(2)Section 56(2)(x)Section 69

facts and in the circumstances of the case and in law, the Ld. AO has erred in levying penalty under section 270A and 270AAC of the Income Tax Act,1961. 7. The Appellant craves leave to add amend and or delete any of the above grounds of Appeals. 10. During