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“levy of penalty”

PenaltySection 271Section 2715,057 judgments

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

Leading authorities on levy of penalty

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.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

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. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

CIT v. Manu Engg
122 ITR 306 · 1980 · High Court
505
citing judgments

When levying a penalty under Section 271(1)(c), the Assessing Officer must clearly specify whether it is for concealment of income or furnishing inaccurate particulars. An ambiguous notice or order using "and/or" for these limbs, or a standard proforma without striking irrelevant clauses, indicates non-application of mind and renders the penalty unsustainable.

Hindustan Steel Ltd. v. State of Orissa
83 ITR 26 · 1972 · Supreme Court
502
citing judgments

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

Judgments citing levy of penalty

Raajendran Indira Raajendran, Chennai vs. ITO, Corporate Ward-2(3), Chennai

In the result, the appeals filed by the assessee for both the assessment years 2018-19 & 2019-20 are allowed for statistical purposes

ITA 3554/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Jan 2026AY 2018-19

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. Nos.3554, 3555 & 3556/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & आयकर अपील सं./I.T.A. Nos. 3557, 3558 & 3559/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 Raajendran Indira Raajendran, Vs. The Income Tax Officer, Z 189, 5Th Street, Anna Nagar, Corporate Ward 2(3), Chennai 600 040. Chennai. [Pan:Aaapi2683M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri H. Yeshwanthkumar, Ca ""थ" की ओर से/Respondent By : Shri Sbr Kumar Laghimsetti, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 27.01.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri H. Yeshwanthkumar, CAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT
Section 2Section 270ASection 271A

Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment years 2018-19 and 2019-20 towards quantum addition as well as levy of penalty under section 271AAC(1) and section 2 I.T.A. Nos.3554 to 3559/Chny/25 270A of the Income Tax Act, 1961 [“Act” in short] for both the assessment ... quantum addition are allowed for statistical purposes. I.T.A. Nos. 3554 and 3556/Chny/2025 for AY 2018-19 5. The assessee also preferred appeals against levy of penalty under sections 271AAC(1) and 270A of the Act in ITA Nos. 3554 and 3556/Chny/2025 respectively. Since we direct

M. Jayaprakash, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, all the five appeals filed by the assessee are stands dismissed

ITA 3529/CHNY/2025[2010-11]Status: DisposedITAT Chennai27 Jan 2026AY 2010-11

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

For Appellant: NoneFor Respondent: Mr.SBR Kumar Laghimsetti, Addl.CIT
Section 148Section 271(1)(C)

short], dated 30.09.2025 for the Assessment Years 2006-07, 2007-08, 2008-09, 2009-10 and 2010- 11 respectively confirming the levy of penalty u/s 271(1)(C) of the Income Tax Act 1961. ITA No.3525,3526,3527,3528 & 3529/Chny/2025 2.0 Since identical facts and issues are involved in five ... estimate basis and therefore no penalty was leviable, placing reliance on certain judicial precedents. However, the AO rejecting the above explanation, proceeded with levy of penalty of Rs.2,80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred

M Jayaprakash, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, all the five appeals filed by the assessee are stands dismissed

ITA 3528/CHNY/2025[2009-10]Status: DisposedITAT Chennai27 Jan 2026AY 2009-10

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

For Appellant: NoneFor Respondent: Mr.SBR Kumar Laghimsetti, Addl.CIT
Section 148Section 271(1)(C)

short], dated 30.09.2025 for the Assessment Years 2006-07, 2007-08, 2008-09, 2009-10 and 2010- 11 respectively confirming the levy of penalty u/s 271(1)(C) of the Income Tax Act 1961. ITA No.3525,3526,3527,3528 & 3529/Chny/2025 2.0 Since identical facts and issues are involved in five ... estimate basis and therefore no penalty was leviable, placing reliance on certain judicial precedents. However, the AO rejecting the above explanation, proceeded with levy of penalty of Rs.2,80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred

M. Jayaprakash, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, all the five appeals filed by the assessee are stands dismissed

ITA 3527/CHNY/2025[2008-09]Status: DisposedITAT Chennai27 Jan 2026AY 2008-09

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

For Appellant: NoneFor Respondent: Mr.SBR Kumar Laghimsetti, Addl.CIT
Section 148Section 271(1)(C)

short], dated 30.09.2025 for the Assessment Years 2006-07, 2007-08, 2008-09, 2009-10 and 2010- 11 respectively confirming the levy of penalty u/s 271(1)(C) of the Income Tax Act 1961. ITA No.3525,3526,3527,3528 & 3529/Chny/2025 2.0 Since identical facts and issues are involved in five ... estimate basis and therefore no penalty was leviable, placing reliance on certain judicial precedents. However, the AO rejecting the above explanation, proceeded with levy of penalty of Rs.2,80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred

M Jayaprakash, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, all the five appeals filed by the assessee are stands dismissed

ITA 3526/CHNY/2025[2007-08]Status: DisposedITAT Chennai27 Jan 2026AY 2007-08

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

For Appellant: NoneFor Respondent: Mr.SBR Kumar Laghimsetti, Addl.CIT
Section 148Section 271(1)(C)

short], dated 30.09.2025 for the Assessment Years 2006-07, 2007-08, 2008-09, 2009-10 and 2010- 11 respectively confirming the levy of penalty u/s 271(1)(C) of the Income Tax Act 1961. ITA No.3525,3526,3527,3528 & 3529/Chny/2025 2.0 Since identical facts and issues are involved in five ... estimate basis and therefore no penalty was leviable, placing reliance on certain judicial precedents. However, the AO rejecting the above explanation, proceeded with levy of penalty of Rs.2,80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred

Jayaprakash, Chennai vs. DCIT, Ncc-8(1), Chennai

In the result, all the five appeals filed by the assessee are stands dismissed

ITA 3525/CHNY/2025[2006-07]Status: DisposedITAT Chennai27 Jan 2026AY 2006-07

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

For Appellant: NoneFor Respondent: Mr.SBR Kumar Laghimsetti, Addl.CIT
Section 148Section 271(1)(C)

short], dated 30.09.2025 for the Assessment Years 2006-07, 2007-08, 2008-09, 2009-10 and 2010- 11 respectively confirming the levy of penalty u/s 271(1)(C) of the Income Tax Act 1961. ITA No.3525,3526,3527,3528 & 3529/Chny/2025 2.0 Since identical facts and issues are involved in five ... estimate basis and therefore no penalty was leviable, placing reliance on certain judicial precedents. However, the AO rejecting the above explanation, proceeded with levy of penalty of Rs.2,80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred

Alka Ashok Jagtap, Kalyan vs. Income Tax Officer, Kalyan

ITA 7524/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Jan 2026AY 2009-10

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokaralka Ashok Jagtap Income Tax Office C-304, Regency Avenue Rani Mansion Syndicate, Murbad Road, Vs. Kalyan, Kalyan Kalyan West, Thane- 421301, Kalyan Pan/Gir No. Ahtpj7760J (Applicant) (Respondent) Assessee By Shri Sunil Jain Revenue By Shri Surendra Mohan, Sr Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026

Section 143(1)Section 143(3)Section 147Section 148Section 154Section 271(1)(c)Section 274

After considering the replies filed by the assessee, the Assessing Officer passed a penalty order dated 16.03.2022 under section 271(1)(c), levying a penalty of Rs. 1,29,410/-, being 100 percent of the tax sought to be evaded, with reference to the assessed income as per the appeal ... been sustained by the CIT(A), the assessee had concealed particulars of income for the year under consideration. 8. Aggrieved by the levy of penalty, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC). The CIT(A), NFAC, by order dated

Mamta Gourav Jain, Mumbai vs. Income Tax Officer - Ward 20(2)(1), Mumbai

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

ITA 7345/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Jan 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Bhavesh ShahFor Respondent: Shri Annavaran Kosuri
Section 147Section 270ASection 56(2)(vii)Section 56(2)(x)

passed u/s. 147 r.w.s. 144B of the Income Tax Act, 1961 („the Act‟) and the appeal in ITA No. 7344/Mum/2025 relates to consequent levy of penalty u/s. 270A of the Act. 2. Briefly, the facts of the case are that during the course of assessment proceedings, the AO observed that ... decide the same afresh, after providing reasonable opportunity to the assessee. 4. It was further submitted that the matter relating to levy of penalty, which also went un-complied with before the Ld.CIT(A) may also be set aside to the file of the Ld.CIT(A). 5. The Ld.DR

Mamta Gourav Jain, Mumbai vs. Income Tax Officer - Ward 20(2)(1), Mumbai

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

ITA 7344/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Jan 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Bhavesh ShahFor Respondent: Shri Annavaran Kosuri
Section 147Section 270ASection 56(2)(vii)Section 56(2)(x)

passed u/s. 147 r.w.s. 144B of the Income Tax Act, 1961 ('the Act') and the appeal in ITA No. 7344/Mum/2025 relates to consequent levy of penalty u/s. 270A of the Act. 2. Briefly, the facts of the case are that during the course of assessment proceedings, the AO observed that ... decide the same afresh, after providing reasonable opportunity to the assessee. 4. It was further submitted that the matter relating to levy of penalty, which also went un-complied with before the Ld.CIT(A) may also be set aside to the file of the Ld.CIT(A). 5. The Ld.DR

Niripraj Singh Sohal, Faridabad vs. ITO Ward 6(1) Ludhiana, Ludhiana

In the result, the appeal of the assessee is partly allowed

ITA 6276/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Jan 2026AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble

For Appellant: Sh. Vinod Kumar, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 139Section 148Section 250Section 271(1)(c)

Page 6276_DEL_2025_Niripraj Singh Sohal vs ITO Ward 3. Although multiple grounds have been raised, the sole substantive issue relates to levy of penalty of Rs. 8,56,794/- u/s 271(1)(c) of the Act. 4. Brief facts are that the assessee had not filed his return

Dinesh Dattatray Shinde, Ratnagiri vs. Income-Tax Officer, Circle-1, Kolhapur

In the result, appeal of the Assessee is allowed

ITA 2287/PUN/2025[2014-15- Q4]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

Section 200ASection 234ESection 250Section 26Q

234E for the delay in filing of statement u/s 26Q by the appellant is upheld. The grounds of appeal relating to levy of penalty u/s 234E of the Act i.e. which are ground no. 1-3 are dismissed.” 2.2 Aggrieved by the order, Assessee filed appeal before this Tribunal. Submission

Dinesh Dattatray Shinde, Ratnagiri vs. Income-Tax Officer, Circle-1, Kolhaur

In the result, appeal of the Assessee is allowed

ITA 2286/PUN/2025[2014-15 - Q2]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

Section 200ASection 234ESection 250Section 26Q

234E for the delay in filing of statement u/s 26Q by the appellant is upheld. The grounds of appeal relating to levy of penalty u/s 234E of the Act i.e. which are ground no. 1-3 are dismissed.” 2.2 Aggrieved by the order, Assessee filed appeal before this Tribunal. Submission

Dinesh Dattatray Shinde, Ratnagiri vs. Income-Tax Officer, Circle -1, Kolhapur

In the result, appeal of the Assessee is allowed

ITA 2285/PUN/2025[2014-15- Q3]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2285, 2286 & 2287/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15(Q3, Q2 & Q4) Dinesh Dattatray Shinde, Vs The Income Tax Officer, 1756, Jutica, Teli Ali, Circle-1, Kolhapur. Ratnagiri – 415612. Pan: Klpdo1360C Appellant/ Assessee Respondent / Revenue Assessee By Shri Anup Bipin Shaha(Virtual) & Shri Rohit Rajeev Shah Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Bench : These Threeappeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2014-15- Q3, Q2 & Q4 Respectively, All Dated 28.07.2025. For The Sake Of Convenience, These Three Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal For A.Y.2014-

Section 200ASection 234ESection 250Section 26Q

234E for the delay in filing of statement u/s 26Q by the appellant is upheld. The grounds of appeal relating to levy of penalty u/s 234E of the Act i.e. which are ground no. 1-3 are dismissed.” 2.2 Aggrieved by the order, Assessee filed appeal before this Tribunal. Submission

Deputy Commissioner, Chennai vs. Natarajan, Coimbatore

In the result, appeals filed by the revenue are dismissed

ITA 2660/CHNY/2024[2019-20]Status: DisposedITAT Chennai23 Jan 2026AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./ Ita Nos. 2661 & 2660 Chny 2024 िनधा*रण वष* /Assessment Year: 2021-22 & 2019-20

For Respondent: Mr. Bipin C.N, CIT
Section 131Section 132Section 132(4)Section 143(1)Section 143(2)Section 143(3)Section 269SSection 271DSection 292CSection 69

Supreme Court held that the onus of proof lies on the department to demonstrate that the statutory conditions necessary for levy of penalty are satisfied. This ruling supports the argument that the department failed to discharge its burden of proving that the appellant had actually received cash loans. Similarly

Nitin Ramchandra Kalambe, Mumbai vs. ITO Ward 2(2), Mumbai

ITA 7424/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Jan 2026AY 2018-19

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

Section 142(1)Section 147Section 272A(1)Section 272A(1)(d)

into consideration, which could not be properly demonstrated before the ld. CIT(A). Be that as it may, since the issue is regarding levy of penalty for non- compliance by the assessee, whereas the assessee has certain material with him, to show that the assessee has attempted for the compliance

Ruby Singh, Delhi vs. DCIT, Central Circle-8, Delhi

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

ITA 4772/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Jan 2026AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Ms. Ruby Singh, Vs. Deputy Commissioner Of R-543, New Rajendra Nagar, Income Tax, New Delhi: 1100 60 Central Circle 8, Pan No. Anaps3827J New Delhi (Appellant) (Respondent)

For Appellant: Shri Mahir Aggarwal, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 271ASection 274Section 68

appreciate that there was neither misreporting of income nor its misrepresentation or suppression of facts of the case so as to uphold the levy of penalty deserves to be quashed and relief be granted to assessee. 2.1 That the learned Commissioner of Income Tax (Appeals) has further failed to appreciate ... dated 27.03.2025 has admitted substantial question of law, thus, when a substantial question of law has been admitted in the high court the levy of penalty is not maintainable. 5. The learned Commissioner of Income Tax (Appeals) has further erred in law and on facts in upholding the penalty order

Sudhir Kumar, Sonipat vs. DCIT Central Circle-31, Delhi

In the result, the appeal being ITA No

ITA 3434/DEL/2025[2021-22]Status: DisposedITAT Delhi23 Jan 2026AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Ms. Amish S Gupt, CIT DR
Section 153ASection 153BSection 153D

orders have been perused by the JCIT. x. The approval given by JCIT is not final. He has directed the assessing officer to levy of penalty under proper section. He has also given various directions to the assessing officer. xi. The JCIT in para 4 of the approval has mentioned

Sudhir Kumar, Sonipat vs. DCIT Central Circle-31, Delhi

In the result, the appeal being ITA No

ITA 3433/DEL/2025[2020-21]Status: DisposedITAT Delhi23 Jan 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Ms. Amish S Gupt, CIT DR
Section 153ASection 153BSection 153D

orders have been perused by the JCIT. x. The approval given by JCIT is not final. He has directed the assessing officer to levy of penalty under proper section. He has also given various directions to the assessing officer. xi. The JCIT in para 4 of the approval has mentioned

Gajullanka Primary Agriculture Co Op Society, Guntur vs. Income Tax Officer, Ward-1, Tenali

In the result, all the four appeals of the Assessee are allowed for statistical purposes

ITA 498/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam22 Jan 2026AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita Nos.495 To 498/Viz./2025 Assessment Years 2018-2019 & 2019-2020 Gajullanka Primary The Income Tax Officer, Agriculture Co-Op Ward-1, Tenali. Society,Avulavaripalem, Vs. Pin – 522 201. Kolluru Mandal, Guntur State Of Andhra District – 522 324. Pradesh Pan Bgapm1891G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri C Subrahmanyam, Ca [Hybrid Mode] राज" व "ारा /Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 22.01.2026 घोषणा की तारीख/Pronouncement: 22.01.2026 आदेश/Order

For Appellant: Sri C Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144Section 147Section 148Section 249(3)Section 250Section 270ASection 271A

return of income filed in response to notice u/sec.148 of the Act. Similarly, the other appeals filed by the assessee against the levy of penalty u/sec.270A to 271AA(c) are required to be adjudicated on merits at the level of the learned CIT(A). Hence, the impugned orders

Gajullanka Primary Agriculture Co Op Society, Guntur vs. Income Tax Officer, Ward-1, Tenali

In the result, all the four appeals of the Assessee are allowed for statistical purposes

ITA 497/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam22 Jan 2026AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Omkareshwar Chidaraआ.अपी.सं /Ita Nos.495 To 498/Viz./2025 Assessment Years 2018-2019 & 2019-2020 Gajullanka Primary The Income Tax Officer, Agriculture Co-Op Ward-1, Tenali. Society,Avulavaripalem, Vs. Pin – 522 201. Kolluru Mandal, Guntur State Of Andhra District – 522 324. Pradesh Pan Bgapm1891G (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri C Subrahmanyam, Ca [Hybrid Mode] राज" व "ारा /Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 22.01.2026 घोषणा की तारीख/Pronouncement: 22.01.2026 आदेश/Order

For Appellant: Sri C Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 144Section 147Section 148Section 249(3)Section 250Section 270ASection 271A

return of income filed in response to notice u/sec.148 of the Act. Similarly, the other appeals filed by the assessee against the levy of penalty u/sec.270A to 271AA(c) are required to be adjudicated on merits at the level of the learned CIT(A). Hence, the impugned orders