आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A. No.2296/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2018-19)

SPR Publications Private VS. Income Tax Officer, Limited, Ward-3(1), Hyderabad. Hyderabad.

PAN: AAKCS2889Q (अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

: Shri P. Murali Mohan Rao, CA करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Assessee Represented by : Shri Sankar Pandi P, Sr.AR राजèवका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Department Represented by : 12/01/2026 सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing : 21/01/2026 घोषणा क(cid:551) तार(cid:547)ख/

Date of Pronouncement ORDER PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 26/11/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 272A(1)(d) of the Income Tax Act, 1961 (for short, “the Act”), dated 18/09/2024 for the Assessment Year (AY) 2018-19. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

“1. The order passed by the Ld. CIT (A) under section 250 dated 26- 11-2025 is erroneous both on facts and in law to the extent the order is prejudice to the interests of the appellant.

2. The Ld. CIT(A) erred in upholding the addition of Rs. 30,000/- u/s

272A(1)(d) without considering the facts of the case, 3. The Ld. CIT(A) ought to have appreciated that penalty cannot be imposed if the assessee has a reasonable cause for the non-

compliance of notices as stipulated in section 273B of the Act.

4. The Ld. CIT(A) ought to have appreciated that the assessee could not respond to the notice as the circumstances were beyond its control and there is no intention of not attending or non-submission of any information and there is no willful attempt not to respond to the notices.

5. The Ld. CIT(A) erred in law and on facts in upholding the levy of penalty u/s 272A(1)(d) of the Act, despite the fact that the quantum assessment itself was completed u/s 147 r.w.s 143(3) r.w.s 144B of the Act, no penalty u/s 272A(1)(d), was legally leviable, and therefore, the impugned order is invalid, unsustainable, and bad in law.

6. Without prejudice to the above, the Ld. CIT(A) erred in confirming the penalty u/s 272A(1)(d) of Rs. 30,000/-, without considering the fact that the quantum assessment itself was quashed by the CIT(A) and upholding such levy is unsustainable and injudicious to the appellant.

7. The appellant may, add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at any time before or at the time of hearing of the appeal.”

2. Succinctly stated, the AO based on information observed that the assessee company during the subject year had though carried out substantial financial transactions, viz., (i) cash deposits in bank accounts: Rs.2,09,40,900/-; (ii) received contractual payments: Rs.4,70,86,517/-; and (iii) received interest (other than interest on securities): Rs.11,29,690/-, but had not filed its return of income for the subject year, initiated proceedings under section 147 of the Act. Thereafter, the order under section 148A(d) of the Act, dated 28/04/2022, was passed by the ACIT, Circle-3(1), Hyderabad, i.e., JAO. Also, notice under section 148 of the Act, dated 28/04/2022, was issued by the ACIT, Circle-3(1), Hyderabad. However, the assessee company failed to comply with the notice issued under section 148 of the Act, dated 28/04/2022, and did not file its return of income in compliance to the same.

3. Ostensibly, a perusal of the assessment recor