Which cases are most cited on Section 271F?

State of Kerala v. C. Velukutty (60 ITR 239) — 78 citing judgments; CIT v. Surendra Prasad Agrawal (275 ITR 113) — 38 citing judgments; 1) Bhagwan Sahai Sharma v. Dy. CIT (174 Taxmann.com 273) — 23 citing judgments; Revenue. I. CIT v. Satish Medical Agencies (292 ITR 163) — 17 citing judgments; 14 (Delhi) 2) Lalit Gulati v. Asstt. CIT (305 Taxmann 11) — 11 citing judgments.

How many judgments are there on Section 271F?

BharatTax indexes 927 ITAT, High Court and Supreme Court judgments that turn on Section 271F of the Income Tax Act, 1961.

Section 271F of the Income Tax Act

Q: What is the leading case on Section 271F of the Income Tax Act?

State of Kerala v. C. Velukutty (60 ITR 239) is the decision most relied on for Section 271F, cited in 78 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.

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

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

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

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

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

citing judgments

Gordhanbhai Devjibhai Kapadia v. ITO

177 Taxmann.com 714 · 2025 · High Court

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

citing judgments

S.M.I.L.E. Micro Finance Ltd. v. ACIT

479 ITR 172 · 2025 · High Court

citing judgments

Commissioner of Income-tax v. Kanubhai Muljibhai Patel

306 ITR 179 · 2008 · High Court

citing judgments

Jayanthi Shri v. Assistant Commissioner of Income-tax, Central Circle-I, Coimbatore

75 Taxmann.com 248 · 2016 · High Court

citing judgments

Judgments on Section 271F

Suman Shukla, Gorakhpur vs. Income Tax Officer, Ward - 2(1), Gorakhpur

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

ITA 134/VNS/2024[2014-2015]Status: HeardITAT Varanasi23 Jul 2026AY 2014-2015

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2014-15 Suman Shukla V. The Income Tax Officer 98-C, Ajad Nagar Ward 2(1) Jungle Tulsiram Gorakhpur Bichhiya, Gorakhpur (U.P) Tan/Pan:Dobps9500B (Applicant) (Respondent) Applicant By: None Respondent By: Shri Sabayasachi Chakraborty, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 29.05.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2014-15. 2.0 The Brief Facts Of The Case Are That The Assessee Did Not File Her Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits Totaling To Rs.11,35,000/- In Her Two Bank Accounts, Viz. Bank Account Nos. 31880521189 & 31337026084, Maintained With State Bank Of India, Gorakhpur, During The Year Under Consideration. The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act’) After Issuing Notice Under Section 148 Of The Act. However, In Response To Notice Under

For Respondent: Shri Sabayasachi Chakraborty, D.R

Section 144Section 147Section 148Section 69A

Late Sh. Jaley Singh Through L/H Smt. Buddhee Devi, Alwar vs. ITO, Ward-1(1), Alwar

The appeals of the assessee are allowed for statistical purposes

ITA 1435/JPR/2025[2016-17]Status: DisposedITAT Jaipur21 Jul 2026AY 2016-17

Bench: Smt. Annapurna Gupta

For Appellant: Sh. P.C. Parwal, CAFor Respondent: Mrs. Aarti Rawat, JCIT

Section 144Section 271FSection 69

Late Sh. Jaley Singh Through L/H Smt. Buddhee Devi, Alwar vs. ITO, Ward-1(1), Alwar

The appeals of the assessee are allowed for statistical purposes

ITA 1434/JPR/2025[2016-17]Status: DisposedITAT Jaipur21 Jul 2026AY 2016-17

Bench: Smt. Annapurna Gupta

For Appellant: Sh. P.C. Parwal, CAFor Respondent: Mrs. Aarti Rawat, JCIT

Section 144Section 271FSection 69

Amit Upadhyay, Bangalore vs. The Assistant Commissioner of Income Tax Circle 3(3)(1), Bangalore

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

ITA 795/BANG/2026[2015-16]Status: DisposedITAT Bangalore21 Jul 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

Section 10Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 156Section 234ASection 250

Madhvi Rameshbhai Bavlecha, Bhavnagar vs. The ITO, Ward-1(8), Bhavnagar

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

ITA 2372/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad17 Jul 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & The Income Tax Officer, Madhvi Rameshbhai Bavlecha, Vs. Ward 1(8), B-1994, Opp. Patel Park, Bhavnagar. Akshardhar Kaliyabid, Bhavnagar H.O, Bhavnagar-364001. [Pan :Aqyb9635 Q] (Appellant) .. (Respondent) Appellant By : Shri Parimalsinh B Parmar, Ar Respondent By: Shri Deependra Kumar , Sr. Dr Date Of Hearing 16.07.2026 Date Of Pronouncement 17.07.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Is Filed By The Assessee Against The Appellate Order Dated 25.04.2024 Passed By The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, Relating To The Assessment Year 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. The Ld. Cit(A) Has Erred, Both In Law & On Facts, In Passing Ex-Parte Order Which Is In Gross Violation Of The Principles Of Natural Justice. 2. In The Facts & Circumstances Of The Case, Action Of Reopening The Assessment Under Section 147 Of The Act Is Not Justified. 3. The Ld. Cit(A) Has Erred, Both In Law & On Facts, In Confirming Addition Of Rs.29,24,799/-In Respect Of Alleged Unaccounted Transaction. Asst. Year : 2013-14 - 2–

For Appellant: Shri Parimalsinh B Parmar, ARFor Respondent: Shri Deependra Kumar , Sr. DR

Section 142(1)Section 147Section 148Section 194Section 234ASection 271(1)(b)Section 271(1)(c)Section 271F