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“Section 274(2)”

Section References (mined)Section 274Section 274(2)66 judgments

UJJAIN SAHAKARI DUGDH SANGH MARYADIT,UJJAIN vs. DCIT/ACIT 1(1) UJJAIN, UJJAIN

Appeal is allowed

ITA 154/IND/2025[2020-21]Status: DisposedITAT Indore27 Feb 2026AY 2020-21

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year: 2020-21 Ujjain Dugdh Sangh (Sah) Dcit/Acit-1(1) Maryadit, Ujjain 1 Dairy Plant, Maxi Road, बनाम/ Naulakha Bid, Vs. Ujjain (Appellant / Assessee) (Respondent / Revenue) Pan: Aaaau0051C Assessee By Ms. Nupur Ladha, Shri Vaibhav Siroliya & Shri V.K. Ladha, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 17.02.2026 Date Of Pronouncement 27/02/2026

Section 142(1)Section 143(2)Section 143(3)Section 144Section 272A(1)(d)Section 274(2)Section 80P

penalty order u/s 272A(1)(d) being the penalty order was passed by the DCIT without approval of Jt. Commissioner as envisaged in section 274(2) of Income Tax Act, 1961. 3. That no proper opportunity was allowed to the appellant to prove his case. 4. The appellant prays

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL. CIT, CENTRAL RANGE-2, HYDERABAD

In the result, the appeals filed by the assessee for the A

ITA 2172/HYD/2025[2021-22]Status: DisposedITAT Hyderabad25 Feb 2026AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274

were initiated not by the Income Tax Officer but by the Inspecting Assistant Commissioner when the matter had been referred to him under section 274(2) of the Act. The proceedings for the imposition of penalty in terms of sub- section (1) of section 271 have necessarily to be initiated

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2 , HYDERABAD

In the result, the appeals filed by the assessee for the\nΑ

ITA 2171/HYD/2025[2020-21]Status: DisposedITAT Hyderabad25 Feb 2026AY 2020-21
For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 269OSection 269SSection 271D

were\ninitiated not by the Income Tax Officer but by\nthe Inspecting Assistant Commissioner when\nthe matter had been referred to him\nunder section 274(2) of the Act. The\nproceedings for the imposition of penalty in\nterms of sub- section (1) of section 271 have\nnecessarily to be initiated

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2, HYDERABAD

In the result, the appeals filed by the assessee for the A

ITA 2165/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Feb 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha G.आ.अपी.सं /Ita Nos. 2164, 2165, 2171 & 2172/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 To 2021-22) M/S. Msn Laboratories (P) Ltd Vs. Additional Cit Hyderabad Central Range-2 Pan:Aadcm6283F Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 21/01/2026 घोषणा की तारीख/Pronouncement: 25/02/2026 आदेश/Order Per. Manjunatha, G. A.M. These Four Appeals Filed By The Assessee Are Directed Against The Separate, But Identical Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad, All Dated 08/10/2025 For The A.Ys 2018-19 To 2021-22 Respectively. Since, Identical Issues Have Been Raised By The Assessee In All These Four Appeals, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Common Consolidated Order.

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 271DSection 274

were initiated not by the Income Tax Officer but by the Inspecting Assistant Commissioner when the matter had been referred to him under section 274(2) of the Act. The proceedings for the imposition of penalty in terms of sub- section (1) of section 271 have necessarily to be initiated

MSN LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ADDL CIT, CENTRAL RANGE-2, HYDERABAD

ITA 2164/HYD/2025[2018-19]Status: DisposedITAT Hyderabad25 Feb 2026AY 2018-19
For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 132Section 153ASection 269Section 269OSection 269SSection 271D

were\ninitiated not by the Income Tax Officer but by\nthe Inspecting Assistant Commissioner when\nthe matter had been referred to him\nunder section 274(2) of the Act. The\nproceedings for the imposition of penalty\nin\nterms of sub- section (1) of section 271 have\nnecessarily to be initiated

RAJESH KUMAR RATHORE,SEHORE vs. INCOME TAX OFFICER, WARD-5, SEHORE, SEHORE

ITA 533/IND/2025[2018-19]Status: DisposedITAT Indore19 Feb 2026AY 2018-19
Section 115BSection 147Section 250Section 253Section 271ASection 274(2)Section 288ASection 69

271AAC(1) is being imposed after the prior\napproval of the Competent Authority i.e Range Head as\nper the provisions laid down in Section 274(2) of the\nIncome Tax Act, 1961. This demand should be paid as\nper the demand notice enclosed.\"\n2.2\nThat the assessee being Aggrieved

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

under reported income). 11. This order has been passed with the prior approval of the Addl. Commissioner of Income tax as per section 274(2) of the Act. 12. Issue Demand Notice & Challan accordingly.” 3. Aggrieved by the penalty order, Assessee filed appeal before ld.CIT(A). Ld.CIT(A) dismissed

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. YASMIN KAPOOR, DELHI

Appeals of the assessee are allowed

ITA 2221/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

levied under section 271(1)(c), holding that the ld. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal by the Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from

ACIT, CENTRAL CIRCLE-19, DELHI, DELHI vs. DEEPA TALWAR, DELHI

Appeals of the assessee are allowed

ITA 2203/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Jan 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanacit, Vs. Deepa Talwar, Central Circle-19, 6/14, Shanti Niketan, Delhi New Delhi (Appellant) (Respondent) Pan: Aaupt4464F

For Appellant: Shri Sanjay Kumar Agarwal, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 143(3)Section 153ASection 153D

levied under section 271(1)(c), holding that the ld. AO had not obtained the previous approval of the IAC as required under section 274(2). On appeal by the Revenue, the Tribunal had reversed the order, holding that the failure to obtain the previous permission from

ONUS PLANTATIONS AND AGRO LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-6, DELHI

In the result, appeal of the assessee is allowed

ITA 5004/DEL/2025[2015-16]Status: DisposedITAT Delhi16 Jan 2026AY 2015-16
Section 127(2)(a)Section 127(3)Section 132(4)Section 153CSection 153DSection 250Section 68Section 69C

levied under section\n271(1)(c), holding that the Id. AO had not obtained the previous\napproval of the IAC as required under section 274(2). On appeal by\nthe Revenue, the Tribunal had reversed the order, holding that the\nfailure to obtain the previous permission from

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

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

concerned penalty under Section 271(l)(c) initiated and imposed by the same Assessing Officer, and not by a different designated authority under Section 274(2).  The ratio therein is confined to cases where the AO himself records satisfaction and initiates penalty proceedings within his jurisdiction.  Distinction: • In the case ... Plus Realtors - which turned on simultaneous initiation by the AO - cannot be imported here. 5. Principle of Harmonious Interpretation • A purposive reading of Sections 274(2) and 27S(l)(c) reveals that the legislature intended to afford a reasonable statutory window to the competent authority after the AO's reference

ASSISTANT COMMISSIONER OF INCOME TAX, ALLAHABAD vs. JYOTI MEDISERVICES LTD., ALLAHABAD

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 1 IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD

JYOTI MEDISERVICES PRIVATE LIMITED, ,ALLAHABAD vs. DCIT, CENTRAL CIRCLE, , ALLAHABAD

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

I.T.A. Nos.113, 114, 115 & 129/Alld/2025 Assessment Years:2011-12 to 13-14 1 IN THE INCOME TAX APPELLATE TRIBUNAL ALLAHABAD

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