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Penalty U/s 272A(1)(d) Deleted: Reasonable Cause Subsequent Compliance Accepted

Case Law Details

TaxGuru Citation
2026 taxguru.in 4324
Case Name
Tarla Jagdish Chauhan Vs CIT (ITAT Mumbai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2017-18
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Tarla Jagdish Chauhan Vs CIT (ITAT Mumbai)

Penalty U/s 272A(1)(d) Deleted: Reasonable Cause Subsequent Compliance Accepted

The assessee was levied a penalty of ₹20,000 under Section 272A(1)(d) for non-compliance with notices issued u/s 142(1). The delay was explained on the ground that the registered email ID was hacked, and notices continued to be sent to that inaccessible email despite subsequent update.

The Tribunal noted that once the assessee became aware, all required details were duly furnished, and importantly, the AO accepted the submissions in full while completing assessment u/s 147. The assessment was not ex-parte, and the returned income was accepted.

Given that there was a reasonable cause for delay and substantial compliance was eventually made, the ITAT held that levy of penalty was unjustified. Accordingly, the penalty was deleted, and the assessee’s appeal was allowed.

FULL TEXT OF THE ORDER OF ITAT MUMBAI

This appeal filed by the assessee is against the order of National Faceless Appeal Centre (NFAC) / CIT(A), Delhi, vide order no. ITBA/NFAC/S/250/2025-26/1083832174(1), dated 18.12.2025, passed against the penalty order by Assessment Unit, u/s. 272A(1)(d) of the Income-tax Act (hereinafter referred to as the “Act”), dated 22.05.2025, for Assessment Year 2017-18.

2. In this appeal assessee is contesting on levy of penalty of Rs.20,000/- u/s. 272A(1)(d).

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,118

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