IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH, MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No. 8661/MUM/2025 (Assessment Year: 2012-13)

Hardik Dayanand Patil, Vs. Income-tax Officer, Swagat, Vartak Road Opp Ward – 4(4), 5XQ75R2, Hira Vidyalaya, Mandvi, Quereshi Mansion, Virar – 401303, Dist – Gopal Krishna Gokhale Palghar, Maharashtra. Marg, Thane West, Thane, Maharashtra -

400602 PAN/GIR No. AWCPP 3932 E (Appellant) .. (Respondent)

Assessee by None.

Revenue by Shri Hemanshu Joshi, Sr.DR Date of Hearing 26/02/2026 Date of Pronouncement 16/03/2026 आदेश / O R D E R PER AMIT SHUKLA (JUDICIAL MEMBER):

1. The present appeal has been preferred by the assessee against the order dated 16.10.2025 passed by the National Faceless Appeal Centre, Delhi, arising out of penalty proceedings initiated under section 271(1)(c) of the Income Tax Act, 1961 for the assessment year 2012–13. The principal grievance raised by the assessee in the present appeal is that the penalty order dated 23.11.2021 passed by the learned Assessing Officer is barred by limitation in terms of the provisions contained in section 275 of the Act, and therefore the said penalty o