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2026 Supreme(Online)(ITAT) 4892

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
BRR Kumar, Vice President, T. R. Senthil Kumar, Judicial Member
Mahaveer Singh – Appellant
Versus
PCIT – Respondent


Advocates:
For the Appellants/Petitioners: P.F. Jain, A.R.
For the Respondents: Alpesh Parmar, CIT-DR

Table of Content
1. reassessment triggered by unreported cash transactions. (Para 1 , 2)
2. pcit invokes section 263 for missed penalty u/s 270a. (Para 3)
3. assessee argues penalty independent of assessment. (Para 4 , 5 , 6)
4. belated return triggers under-reporting penalty u/s 270a(2)(b). (Para 7 , 8)
5. courts differ; allahabad hc supports revision for penalty omission. (Para 9)
6. revision order upheld; appeal dismissed. (Para 10 , 11)

आदेश/ORDER

PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER

This appeal is filed by the Assessee as against Revision order dated 25-03-2025 passed by the Principal Commissioner of Income Tax, Ahmedabad-1, arising out of the assessment order passed under section 143(3) r.w.s. 147 of the (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19.

2. Brief facts of the case is that the assessee is an individual has not filed the Return of Income for the Asst. Year 2018-19. Information received from the insight portal of the Department that the assessee made cash deposit of Rs.1,26,85,410/- and withdrawal of Rs.7,45,118/- in his ICICI Bank account, Ahmedabad-Relief Road Branch during the Financial Year 2017-18 but not filed the Return of Income.

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