Section 271F of the Income Tax Act

The decision most relied on for Section 271F is State of Kerala v. C. Velukutty (60 ITR 239), cited in 78 of the 927 judgments on BharatTax that turn on this section.

Leading authorities on Section 271F

State of Kerala v. C. Velukutty
60 ITR 239 · 1966 · Supreme Court
78
citing judgments

A best judgment assessment must be based on wisdom, truth, and legal principles, not arbitrary caprice. While it involves estimation and guesswork, this must have a reasonable nexus to available material and the case's circumstances.

CIT v. Surendra Prasad Agrawal
275 ITR 113 · 2005 · High Court
38
citing judgments

The omission by an Income Tax Officer to initiate penalty proceedings during the assessment, when there is an observation of under-reporting or mis-reporting of income, renders the assessment order erroneous and prejudicial to the interests of the Revenue, granting the Commissioner jurisdiction to revise such an order under Section 263.

1) Bhagwan Sahai Sharma v. Dy. CIT
174 Taxmann.com 273 · 2025 · High Court
23
citing judgments

Reassessment proceedings initiated for AY 2015-16 after April 1, 2021, are barred by limitation and invalid, as per the amended provisions of the Finance Act, 2020.

Revenue. I. CIT v. Satish Medical Agencies
292 ITR 163 · 2007 · High Court
17
citing judgments

A conscious act by the assessee to hide information from the department is a key factor in upholding revenue assessments and penalties.

14 (Delhi) 2) Lalit Gulati v. Asstt. CIT
305 Taxmann 11 · High Court
11
citing judgments
Gordhanbhai Devjibhai Kapadia v. ITO
177 Taxmann.com 714 · 2025 · High Court
10
citing judgments

A notice under section 148 of the Income Tax Act issued after March 31, 2021, is invalid if it relies on the extended time limit provided by the Taxation and Other Laws (Relaxation of Certain Provisions) Act, 2020, for assessment years prior to 2021-22.

Manubhai A. Sheth v. N. D. Nirgudkar, Second ITO
128 ITR 87 · 1981 · High Court
9
citing judgments
S.M.I.L.E. Micro Finance Ltd. v. ACIT
479 ITR 172 · 2025 · High Court
6
citing judgments
Commissioner of Income-tax v. Kanubhai Muljibhai Patel
306 ITR 179 · 2008 · High Court
4
citing judgments
Jayanthi Shri v. Assistant Commissioner of Income-tax, Central Circle-I, Coimbatore
75 Taxmann.com 248 · 2016 · High Court
4
citing judgments

Judgments on Section 271F

Bombay Tyres, Navi Mumbai vs. Income Tax Officer-15(1)(1), Mumbai

In the result, the appeal is dismissed

ITA 6593/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Saktijit Dey, Vp & Shri Makarand Vasant Mahadeokar, Am Bombay Tyres Income Tax Officer-15(1)(1) Room No. 456, 4Th Floor, 23, Arenja Corner, Sector -17, Vashi, Navi Mumbai-400 703 Vs. Aaykara Bhavan, M. K. Road, Mumbai-400 020 Pan/Gir No. Aagcb 1604 E (Appellant) : (Respondent) Appellant By : None Respondent By : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 13.03.2026 Date Of Pronouncement : 13.03.2026 O R D E R Per Makarand V. Mahadeokar, Am : This Is An Appeal By The Assessee Against Order Dated 22.08.2025 Of First Appellate Authority, Pertaining To Assessment Year (A.Y.) 2017-18. 2. The Assessee Has Filed Application Dated 09.03.2026, Seeking Permission To Withdraw The Appeal. The Contents Of The Said Letter Are As Under: Sub: Application For Withdrawal Of Appeal (Ita 6593/Mum/2025) Assessment Year 2017-18 Pan: Aagcb1604E With Reference To The Above-Captioned Appeal, The Appellant Respectfully Submits As Under: 1. The Present Appeal Has Been Filed Against The Order Dated 22Nd August 2025 Passed By The National Faceless Appeal Centre, Delhi, Confirming The Levy Of Penalty Under Section 271F Of The Income-Tax Act, 1961 Amounting To Rs.5,000/-. 2. Upon Reconsideration Of The Matter, The Appellant Does Not Wish To Press The Present Appeal. 3. The Appellant Has Paid The Penalty Demand Of Rs.5,000/- Arising Pursuant To The Impugned Penalty Order U/S.271F Dated 21 March, 2025. 2 Bombay Tyres Vs. Ito 4. The Appellant Therefore Seeks Permission Of The Hon'Ble Tribunal To Withdraw The Present Appeal & Dismiss The Same As Withdrawn/Not Pressed. Thanking You, 3. The Learned Departmental Representative (Ld. Dr For Short) Has No Objection To The Assessee’S Prayer.

For Appellant: NoneFor Respondent: Shri Bhagirath Ramawat, Sr. DR
Section 271F