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“Section 275(1)”

Section References (mined)Section 275Section 275(1)152 judgments

VIMAL TODI,INDORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, INDORE

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

being contested before us, is that the penalty-order dated 28.03.2019 u/s 271D passed by AO was barred by time-limitation prescribed in section 275(1)(c). 5. This very issue stands already adjudicated by learned co-ordinate bench in favour of assessee in aforesaid earlier order dated 25.10.2024. Since ... section 275. The assessee also raised this very issue before CIT(A) but the CIT(A) referred following provision of section 275(1)(c): “275(1) No order imposing a penalty under this Chapter shall be passed – (a) XXX (b) XXX (c) in any other case, after the expiry

VICKY NAVANI,JABALPUR vs. INCOME TAX OFFICER, WARD 1(3), JABALPUR, WARD )), JABALPUR

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

ITA 124/JAB/2024[2016-17]Status: DisposedITAT Jabalpur13 Feb 2026AY 2016-17

Bench: Shri Anadee Nath Misshra

Section 253(3)Section 271Section 271BSection 273BSection 275Section 44A

through ITBA e-filing portal. 5. The provision of the section 275 have been clearly misunderstood and misinterpreted by the assessee. Applicability of section 275(1)(c) is not warranted in the case of assessee because ne proceedings, in course of which action for imposition of penalty has been initiated ... Ld.JAO was as follows- 5. The provision of the section 275 have been clearly misunderstood and misinterpreted by the assessee. Applicability of section 275(1)(c) is not warranted in the case of assessee because no proceedings, in course of wich action for imposition of penalty has been initiated, prior

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, CENTRAL RANGE-4,, NEW DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2926/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDL. COMMISSIONER OF INCOME TAX, CENTRAL RANGE - 04,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2925/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2924/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2923/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2922/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2921/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2920/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

SANJEEV JAI NARAIN AEREN,DELHI vs. ADDITIONAL COMMISSIONER OF INCOME TAX CENTRAL RANGE-4,, DELHI

Accordingly, the appeals filed by the assessee arising out of penalty u/s 271D for AYs 2015-16 & 2018-19 are allowed

ITA 2919/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Rajeshwar Prasad Painuly, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 143(3)Section 269SSection 271DSection 271ESection 274(2)Section 275(1)(c)Section 27l

legally valid and within the prescribed limitation period. • The assessee has sought to contend that the penalty order is barred by limitation under Section 275(1)(c) of the Act, relying upon various judicial pronouncements. The Revenue humbly submits that the facts of the present case are materially distinguishable from ... when the Addl. CIT issued the show-cause notice, in exercise of statutory jurisdiction vested in him. 3. Legal Position on Limitation under Section 275(1)(c) • Section 275(1)(c) of the Act provides that no order imposing a penalty shall be passed after expiry of six months from

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. JUGAL KISHORE GARG ALIAS SH. JUGAL KISHORE DEREWALA, JAIPUR

ITA 1320/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Nov 2025AY 2016-17
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

nClause (a) of Sub-section (1) of Section 275 cannot be attracted to such\nproceedings. If that were not so Clause (c) of Section 275(1) would be redundant\nbecause otherwise as a matter of fact every penalty proceeding is usually\nInitiated when during some proceedings such default is noticed ... amount to repayment\nof loan or deposits willin the meaning of Section 269SS or Section 269T and on\nthe ground that limitation under Section 275(1)(c) applies to such proceedings we\nhold in favour of the respondents\"\nThus the order in barred by imitation on both the points

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. JUGAL KISHORE GARG ALIAS SH. JUGAL KISHORE DEREWALA, JAIPUR

ITA 1319/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Nov 2025AY 2012-13
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

nClause (a) of Sub-section (1) of Section 275 cannot be attracted to such\nproceedings. If that were not so Clause (c) of Section 275(1) would be redundant\nbecause otherwise as a matter of fact every penalty proceeding is usually\nInitiated when during some proceedings such default is noticed ... amount to repayment\nof loan or deposits willin the meaning of Section 269SS or Section 269T and on\nthe ground that limitation under Section 275(1)(c) applies to such proceedings we\nhold in favour of the respondents\"\nThus the order in barred by imitation on both the points

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. JUGAL KISHORE GARG ALIAS SH. JUGAL KISHORE DEREWALA, JAIPUR

ITA 1318/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Nov 2025AY 2012-13
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

nClause (a) of Sub-section (1) of Section 275 cannot be attracted to such\nproceedings. If that were not so Clause (c) of Section 275(1) would be redundant\nbecause otherwise as a matter of fact every penalty proceeding is usually\ninitiated when during some proceedings such default is noticed ... amount to repayment\nof loan or deposits willin the meaning of Section 269SS or Section 269T and on\nthe ground that limitation under Section 275(1)(c) applies to such proceedings we\nhold in favour of the respondents\"\nThus the order in barred by imitation on both the points

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPURQ, JAIPUR vs. JUGAL KISHORE GARG ALIAS SH. JUGAL KISHORE DEREWALA, JAIPUR

ITA 1317/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Nov 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

Clause (a) of Sub-section (1) of Section 275 cannot be attracted to such proceedings. If that were not so Clause (c) of Section 275(1) would be redundant because otherwise as a matter of fact every penalty proceeding is usually Initiated when during some proceedings such default is noticed ... amount to repayment of loan or deposits willin the meaning of Section 269SS or Section 269T and on the ground that limitation under Section 275(1)(c) applies to such proceedings we hold in favour of the respondents" Thus the order in barred by imitation on both the points” Section

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

ITA 1178/JPR/2025[2021-22]Status: DisposedITAT Jaipur13 Nov 2025AY 2021-22
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course ... Additional CIT issuing notice\nunder Section 271-E of the Act. The Additional CIT ought to have been conscious of the\nlimitation under Section 275 (1) (c). i.e., that no order of penalty could have been passed\nunder Section 271-E after the expiry of the financial year in which

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

ITA 1177/JPR/2025[2021-22]Status: DisposedITAT Jaipur13 Nov 2025AY 2021-22
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course ... action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

ITA 1176/JPR/2025[2020-21]Status: DisposedITAT Jaipur13 Nov 2025AY 2020-21
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course ... action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

ITA 1175/JPR/2025[2020-21]Status: DisposedITAT Jaipur13 Nov 2025AY 2020-21
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course ... Additional\nCIT issuing notice under Section 271-E of the Act. The Additional CIT ought to have\nbeen conscious of the limitation under Section 275 (1) (c). i.e., that no order of penalty\ncould have been passed under Section 271-E after the expiry of the financial year in\nwhich

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result the appeal of the revenue in ITA no

ITA 1174/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20
For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course ... action for imposition of penalty is\ninitiated, whichever period expires later.\nIn this case the limitation period is governed by clause (c) of Section 275(1). As\nper this section, the penalty order is to be passed before the end of the FY. in\nwhich the proceeding in the course

DY. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. M/S GOKUL KRIPA COLONIZERS & DEVELOPERS PVT. LTD., JAIPUR

In the result, the appeals of the revenue stands dismissed, and the

ITA 1170/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Nov 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: MS. Alka Gautam, CIT-DR
Section 271DSection 271E

action for imposition of penalty is initiated, whichever period expires later. In this case the limitation period is governed by clause (c) of Section 275(1). As per this section, the penalty order is to be passed before the end of the FY. in which the proceeding in the course ... Additional CIT issuing notice under Section 271-E of the Act. The Additional CIT ought to have been conscious of the limitation under Section 275 (1) (c). i.e., that no order of penalty could have been passed under Section 271-E after the expiry of the financial year in which

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