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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

Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Limited, Patna vs. Assessment Unit, Patna

In the result, the ITA Nos

ITA 434/PAT/2025[2020-2021]Status: DisposedITAT Patna09 Jan 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

Section 143(3)Section 250Section 270ASection 271ASection 80P

adequate opportunity of being heard to the assessee. Accordingly, ITA No. 429/Patna/2025 is allowed for statistical purposes. 9. ITA No. 430/Patna/2025 relates to penalty under Section 270A for the A.Y 2018–19. This appeal arises out of the penalty imposed under section 270A, which is consequential to the assessment order ... 431/Patna/2025 is allowed for statistical purposes. 11. Similarly, ITA No.432/Pat/2025 relates to penalty under section 271AAC(1), ITA No.433/Pat/2025 relates to penalty under section 270A and ITA No. 434/Pat/2025 relates to penalty under section 272A(1)(d) of the Act. All these penalties arise from the assessment order

Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Limited, Patna vs. Assessment Unit, Patna

In the result, the ITA Nos

ITA 431/PAT/2025[2020-2021]Status: DisposedITAT Patna09 Jan 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

Section 143(3)Section 250Section 270ASection 271ASection 80P

adequate opportunity of being heard to the assessee. Accordingly, ITA No. 429/Patna/2025 is allowed for statistical purposes. 9. ITA No. 430/Patna/2025 relates to penalty under Section 270A for the A.Y 2018–19. This appeal arises out of the penalty imposed under section 270A, which is consequential to the assessment order ... 431/Patna/2025 is allowed for statistical purposes. 11. Similarly, ITA No.432/Pat/2025 relates to penalty under section 271AAC(1), ITA No.433/Pat/2025 relates to penalty under section 270A and ITA No. 434/Pat/2025 relates to penalty under section 272A(1)(d) of the Act. All these penalties arise from the assessment order

Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Limited, Patna vs. Assessment Unit, Patna

In the result, the ITA Nos

ITA 430/PAT/2025[2018-2019]Status: DisposedITAT Patna09 Jan 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

Section 143(3)Section 250Section 270ASection 271ASection 80P

adequate opportunity of being heard to the assessee. Accordingly, ITA No. 429/Patna/2025 is allowed for statistical purposes. 9. ITA No. 430/Patna/2025 relates to penalty under Section 270A for the A.Y 2018–19. This appeal arises out of the penalty imposed under section 270A, which is consequential to the assessment order ... 431/Patna/2025 is allowed for statistical purposes. 11. Similarly, ITA No.432/Pat/2025 relates to penalty under section 271AAC(1), ITA No.433/Pat/2025 relates to penalty under section 270A and ITA No. 434/Pat/2025 relates to penalty under section 272A(1)(d) of the Act. All these penalties arise from the assessment order

Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Limited, Patna vs. Assessment Unit, NFAC, Delhi

In the result, the ITA Nos

ITA 429/PAT/2025[2018-2019]Status: DisposedITAT Patna09 Jan 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.429To 434/Pat/2025 Assessment Year: 2018-19 & 2020-21 Vaishal Patliputra Dugdh Utpadak Sahkari Sangh Ltd……………………………...………………. …………………....Appellant Feeder Balancing Dairy, Phulwarishariff, Patna, Bihar – 801505. [Pan: Aaaav8463B] Vs. Assessment Unit, Delhi.…..…..……………..………………….…..... Respondent Appearances By: Shri Nishan Maitin, Fca Appeared On Behalf Of The Appellant. Md. A H Chowdhury, Cit-Dr Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 09, 2026 आदेश / Order Per Sonjoy Sarma: The Captioned Appeals Filed By The Assessee Is Directed Against The Orders Dated 07.04.2025 Passed By The Cit(A)-Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’). Since All The Above Appeals Have Been Filed By The Same Assessee, Involve Common Facts & Arise Out Of Related Assessment & Penalty Proceedings, They Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. There Are Delays In Filing Of The Appeals, As Under:

Section 143(3)Section 250Section 270ASection 271ASection 80P

adequate opportunity of being heard to the assessee. Accordingly, ITA No. 429/Patna/2025 is allowed for statistical purposes. 9. ITA No. 430/Patna/2025 relates to penalty under Section 270A for the A.Y 2018–19. This appeal arises out of the penalty imposed under section 270A, which is consequential to the assessment order ... 431/Patna/2025 is allowed for statistical purposes. 11. Similarly, ITA No.432/Pat/2025 relates to penalty under section 271AAC(1), ITA No.433/Pat/2025 relates to penalty under section 270A and ITA No. 434/Pat/2025 relates to penalty under section 272A(1)(d) of the Act. All these penalties arise from the assessment order

Kumar Properties and Real Estate Private Limited, Pune vs. Assistant Commissioner of Income Tax, Circle 14, Pune

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

ITA 2798/PUN/2025[2017-18]Status: DisposedITAT Pune09 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Basavaraj Hiremath, Addl.CIT
Section 142(1)Section 143(2)Section 14ASection 270A

restricted to Rs.7,71,033, wherein disallowance is computed by allocating common admin expenses between exempt income and taxable income. Initiation of penalty under section 270A of the Act 9. The learned AO has erred in initiating penalty proceedings on the above under section 270A of the Act. The Appellant

Income Tax Officer, Ranchi, Jharkhand vs. Amba Carbonisation Pvt. Ltd., Ranchi, Jharkhand

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B

IN THE INCOME TAX APPELLATE TRIBUNAL BENCH-RANCHI VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and Shri

Ishares Core Msci Total International Stock Etf (As A Successor to Ishare Core Taotal International Stock Mauritius Company ), Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

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

ITA 6774/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

interest has been levied; Ground of Appeal No. 13: Initiation of penal proceedings under section 270A of the Act 20. erred in initiating penalty under section 270A of the Act alleging underreporting of income by the Appellant.” 4. Ground no.1 is general in nature. Therefore, the same needs no specific ... Ground of Appeal No. 7: Initiation of penal proceedings under section 270A of the Act 7. erred in initiating penalty under section 270A of the Act alleging underreporting of income by the Appellant.” 34. The issue arising in Grounds no.1 to 4, raised in assessee’s appeal, pertains

Ishares Core Msci Emerging Markets Etf (As A Successor to Ishares Core Emerging Markets Mauritius Company, Mumbai vs. DCIT (Tp) 2(2)(2), Mumbai

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

ITA 6051/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

interest has been levied; Ground of Appeal No. 13: Initiation of penal proceedings under section 270A of the Act 20. erred in initiating penalty under section 270A of the Act alleging underreporting of income by the Appellant.” 4. Ground no.1 is general in nature. Therefore, the same needs no specific ... Ground of Appeal No. 7: Initiation of penal proceedings under section 270A of the Act 7. erred in initiating penalty under section 270A of the Act alleging underreporting of income by the Appellant.” 34. The issue arising in Grounds no.1 to 4, raised in assessee’s appeal, pertains

Ishares Msci All Country Asia Ex Japan Etf, Mumbai vs. DCIT (Int. Tax)-2(2)(2), Mumbai

ITA 6050/MUM/2025[2022-23]Status: DisposedITAT Mumbai02 Jan 2026AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

interest has been levied; Ground of Appeal No. 13: Initiation of penal proceedings under section 270A of the Act 20. erred in initiating penalty under section 270A of the Act alleging underreporting of income by the Appellant. 4. Ground no.1 is general in nature. Therefore, the same needs no specific

Inu Exports Private Limited, Mumbai vs. ITO 12(2)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4070/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Jan 2026AY 2017-18

Bench: Shri Pawan Singh & Smt. Renu Jauhri(Hybrid Hearing) Inu Exports Private Limited Ito, 12(2)(2), Mumbai Room No. 145, 1St Floor, Aayakar Office No. 33, Shrinaman Plaza, Vs Behind Shoppers Stop Kandivali, Bhavan, M.K. Road, Mumbai, Maharashtra - 400067. Mumbai – 400020. [Pan: Aaaci 6806 M] Appellant / Assessee Respondent / Revenue

Section 143(3)Section 154Section 254(1)Section 270Section 270ASection 274

goods, so it cannot be considered as a trading transaction. The claim of loss was disallowed by treating a speculative loss and initiated penalty under section 270A for under reporting income. The assessing officer levied the penalty of Rs. 15.18 crore under section 270A. Before levying the penalty ... held that in his case, the provision of section 270A is clearly applicable. The AO accordingly levied the penalty under section 270A @50% of tax liability for under reporting income. The AO levied penalty of Rs. 15, 19,85,920/- in his order dated 13.01.2022. 3. Aggrieved by the penalty

Bechtel Ltd, London vs. ACIT, Circle 1(1)(2), International Taxation, New Delhi

In the result, appeal of the assessee is allowed

ITA 756/DEL/2023[2020-21]Status: DisposedITAT Delhi31 Dec 2025AY 2020-21
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

That on the facts and the circumstances of the case and in law, the Ld. AO has erred in proposing to levy penalty under Section 270A(9)(a) of the Act. 10. The above grounds of appeal are independent and without prejudice to one another. 11. The Appellant prays

Bechtel Limited, London vs. ACIT, Circle Int. Tax 1(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1816/DEL/2022[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19
Section 143(2)Section 143(3)Section 144C(13)Section 44DSection 9(1)(vii)

That on the facts and the circumstances of the case and in law, the Ld. AO has erred in proposing to levy penalty under Section 270A(9)(a) of the Act. 10. The above grounds of appeal are independent and without prejudice to one another. 11. The Appellant prays

Granules India Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 1295/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139(1)Section 143(1)Section 143(3)Section 154Section 155(18)Section 270A

Thereafter, the AO, vide his order passed under Section 270A of the Act, dated 23/02/2023, imposed upon the assessee company, the penalty under Section 270A of Rs. 82,63,156 for under-reporting of income w.r.t the disallowance of HEC of Rs. 4,81,53,591/-. 6. Aggrieved, the assessee ... supra) may not be disallowed. The Ld. AR submitted that such voluntary surrender, founded on a debatable legal issue, could not attract a penalty under Section 270A of the Act. The Ld. AR to buttress his contention, submitted that Section 155(18) of the Act, that had been inserted vide

Gunmala Jain, Ajmer vs. Income Tax Officer, WD-2(2), Ajmer

Appeal of the assessee is dismissed

ITA 1262/JPR/2025[2019-20]Status: DisposedITAT Jaipur22 Dec 2025AY 2019-20

Bench: SMT. ANNAPURNA GUPTA, AM आयकर अपील सं. / ITA No.1262/JPR/2025 निर्धारणवर्ष / AssessmentYears :2019-20 Gunmala Jain, बनाम 28 Abhi Lash Nikunj, Kalyan Vs. Income Tax Officer, Ward-2(2) Colony, Ajmer Road Kekri, Ajmer स्थायीलेखा सं. / जीआईआर सं./ PAN/GIR No.: ABRPJ 4764E Ajmer अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assesseeby :Sh. Sunil Porwal, CA (Thr.V.C.) राजस्व की ओर से / Revenue by : Sh. Gautam Singh Choudhary (Addl. CIT) सुनवाई की तारीख / Date of Hearing : 18/1

For Appellant: Sh. Sunil Porwal, CA (Thr.V.C.)For Respondent: Sh. Gautam Singh Choudhary
Section 148Section 250Section 270ASection 80G

/National Faceless Appeal Centre (NFAC), under Section 250 of the Income Tax Act, 1961, (hereinafter referred to as “Act”), confirming the levy of penalty under Section 270A of the Act. 2. The grounds raised by the assessee read as under:- 2 Gunmala Jain 1. The ld. CIT(A) confirming ... under Section 147 of the Act. 10. Considering the above facts and taking note of the law with regard to the levy of penalty under Section 270A of the Act, we shall now proceed to deal with each contention of the learned counsel for the assessee before us. We shall

Smt Suruchi Satish Sarmalkar, Mumbai vs. ITO Ward-32(1)(1), Mumbai

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

ITA 5942/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain& Shri Om Prakash Kant

Section 154Section 250Section 270A

case was made under the deeming provisions of Section 56(2)(x) of the Act. The contention of the assessee is that no penalty under Section 270A of the Act can be imposed for such deeming addition. It is found that the case laws relied upon by the assessee were ... Alrameez Construction (P.) Ltd. v. CIT/NFAC [2023] 152 taxmann.com 382/202 ITD 379 (Mumbai - Trib.) is found to be in the context of penalty under Section 270A of the Act for under-reporting the income. In that case also, the addition was made under Section

Krishi Upaj Mandi Samiti, Chaapeheda vs. Neac, Delhi

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

ITA 56/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

observe that ITA No. 54/Ind/2025 relates to levy of penalty under Section 272A(1)(d) and ITA No. 56/Ind/2025 related to levy of penalty under Section 270A of the Act. Since both these appeals have been dismissed by the Ld. CIT(A) on account of non-appearance by the assessee

Krishi Upaj Mandi Samiti, Chaapeheda, Chhapiheda vs. Neac, Delhi

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

ITA 55/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

observe that ITA No. 54/Ind/2025 relates to levy of penalty under Section 272A(1)(d) and ITA No. 56/Ind/2025 related to levy of penalty under Section 270A of the Act. Since both these appeals have been dismissed by the Ld. CIT(A) on account of non-appearance by the assessee

Krishi Upaj Mandi Samiti, Chaapeheda vs. Neac, Delhi

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

ITA 54/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

observe that ITA No. 54/Ind/2025 relates to levy of penalty under Section 272A(1)(d) and ITA No. 56/Ind/2025 related to levy of penalty under Section 270A of the Act. Since both these appeals have been dismissed by the Ld. CIT(A) on account of non-appearance by the assessee

Krishna Prabha Sundarapandy, Kanchipuram vs. DCIT, Corporate Circle-6(2), Chennai

In the result, the appeal of the assessee is allowed

ITA 2304/CHNY/2025[2022-23]Status: DisposedITAT Chennai17 Dec 2025AY 2022-23

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2304/Chny/2025 िनधा%रण वष% /Assessment Year: 2022-23

For Appellant: Mr. S. Jayakumar, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 143(3)Section 250Section 270A

provisions of Section 270A(2) or 270A(9) of the Act the assessee had misreported or under-reported his income, no penalty under Section 270A of the Act was leviable. Krishna Prabha Sundarapandy :- 4 -: 18. We find that the appeal has to succeed on the ground that the phraseology

August Jewellery Pvt Ltd, Bengaluru vs. D.C.I.T., Circle 1(1)(1), Bengaluru

ITA 1420/BANG/2025[2022-2023]Status: DisposedITAT Bangalore15 Dec 2025AY 2022-2023

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Miraj Shah, ARFor Respondent: Shri. Shivanand H Kalakeri, CIT(DR)(ITAT), Bangalore
Section 270ASection 271ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY