This compilation indexes twelve tribunal and High Court rulings — spanning June 2022 through August 2026 — in which Section 271(1) of the Income-tax Act, 1961 was a central or connected provision. The cases originate from ITAT benches at Jodhpur, Chennai, Chandigarh, Delhi, Amritsar, Mumbai, Raipur, and Cuttack, as well as the Madhya Pradesh High Court. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for locating Section 271(1) penalty litigation across Indian tribunals and courts.

Research index only. This page catalogues publicly available court and tribunal orders for reference purposes. Nothing on this page constitutes legal advice, tax advice, or an opinion on the merits of any dispute. Readers must consult qualified legal counsel and verify the full text of each judgment before relying on it.

The statutory framework in one paragraph

Section 271(1) of the Income-tax Act, 1961 empowers the Assessing Officer, the Commissioner (Appeals), or the Principal Commissioner or Commissioner to levy a penalty in specified circumstances arising in the course of assessment or other proceedings. The principal limbs of the provision include, among others, failure to comply with a notice issued under the Act and concealment of income or furnishing of inaccurate particulars of income — the latter commonly referred to by reference to clause (c) of the sub-section. The provision is procedural-cum-penal in character and operates in conjunction with related provisions governing the initiation and time-limit for penalty proceedings.

The 12 rulings

1. Income Tax Officer Ward 2(1 )Udaipur vs Chaitaanya Kochar, Wardha

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 11 August 2026
Sections engaged: 132(1), 143(3), 153A, 260A, 271(1), 271(1)(c), 275
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the ITAT Jodhpur Bench in ITA Nos. 429 & 430/Jodh/2023, relating to Assessment Years 2002-03 and 2005-06. Per the source preview, a search was conducted and consequent assessments were framed; those assessments were subsequently challenged before the Bombay High Court on jurisdictional grounds, and the High Court quashed the transfer order as well as the consequential assessments; fresh proceedings followed thereafter, with penalty provisions also engaged in the course of the litigation.

2. Drillcon (Raj) Private vs ACIT Circle-1 Udaipur, Udaipur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 29 July 2026
Sections engaged: 143(3), 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 798/Jodh/2025) was preferred by the assessee against an order passed under the relevant assessment provision by the National Faceless Appeal Centre, which had dismissed the assessee's appeal; the assessee is a private limited company engaged in dealing of earth movers, construction, heavy and commercial vehicles, and filed its income tax return for Assessment Year 2014-15 on 16 December 2016. The ITAT Jodhpur bench heard the matter on 28 April 2026 and pronounced the order on 29 July 2026.

3. Kulandaivel Selvam, Namakkal vs ITO, Ward-1, Namakkal

Bench: Income Tax Appellate Tribunal - Chennai
Date: 7 July 2026
Sections engaged: 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 1344 to 1347/Chny/2026) covered Assessment Years 2019-20, 2021-22, 2022-23, and 2023-24; per the source preview, the dispute involved allegations of failure to get accounts audited or failure to furnish a report of such audit as required, which formed the factual substratum for the penalty proceedings engaged in the appeals.

4. Hydro Engineering College vs Income Tax Officer Ward Bilaspur

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 2 July 2026
Sections engaged: 10, 11, 14, 144B, 147, 148, 270A, 271(1), 2B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 1183 and 1184/Chandi/2025) relate to Assessment Year 2019-20 and were filed by the assessee challenging confirmation of a quantum addition on merits and the consequential levy of penalty; per the source preview, the assessment was framed under sections 147 read with 144B by the Assessing Officer on 12 March 2024, and the sole grievance of the assessee in the quantum appeal included denial of a deduction, with the penalty appeal being consequential to the quantum dispute.

5. Mohini Chandnani Charitable vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 10 June 2026
Sections engaged: 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1341/DEL/2026) pertains to Assessment Year 2011-12 and is directed against the order of the National Faceless Appeal Centre dated 08-08-2025, which arose from a penalty order dated 28-03-2019; per the source preview, the appeal was time-barred by 97 days and the assessee filed a condonation application citing sufficient cause, with the Bench noting it found merit in the condonation plea.

6. Shri Yash Paul Malhotra, Jalandhar vs Deputy Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 13 August 2025
Sections engaged: 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 379/Asr/2024) relates to Assessment Year 2016-17 and was filed by the assessee before the ITAT Amritsar Bench; per the source preview, the order extract references judicial precedents being distinguished on facts, with the assessee's case being contrasted against situations involving untenable claims and unexplained surrenders, suggesting the central issue was whether the facts warranted imposition of penalty.

7. Ishtiaq Ahmad Rather, Jammu And Kashmir vs Income Tax Office Ward 1, Srinagar

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 10 September 2024
Sections engaged: 68, 271(1)
Outcome: Taxpayer succeeded
Procedural / substantive ground: Both appeals (ITA Nos. 316 & 317/Asr/2024) were filed by the assessee against the order of the CIT(A), NFAC, dated 19.02.2024 for Assessment Year 2016-17, arising out of an assessment order and a penalty order; per the source preview and outcome reasoning, the Tribunal allowed both appeals, with the assessee having challenged, among other things, confirmation of an addition of Rs. 98,53,000/- on account of cash deposited, and the Tribunal's disposal was in favour of the taxpayer.

8. M/S Sanofi India Ltd (Formerly Known As Aventis Pharma Limited) vs The ACIT Rg 8(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 31 October 2023
Sections engaged: 92C, 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Multiple ITA numbers were taken up together before the ITAT Mumbai Bench covering Assessment Years 2003-04 and 2004-05; per the source preview, the appeals involved the company formerly known as Aventis Pharma Limited, with both assessee-filed and revenue-filed appeals consolidated, and the proceedings engaged both the transfer pricing provision and the penalty provision.

9. Khomram Chandrawanshi (HUF), Raipur vs Income Tax Officer-4(1), Raipur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 9 August 2023
Sections engaged: 271(1), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 165/RPR/2022) is directed against the order of CIT(A), NFAC, Delhi dated 21.07.2022, which in turn arose from a penalty order dated 23.06.2017 for Assessment Year 2014-15; per the source preview, the assessee challenged the levy of a penalty of Rs. 5,19,400/- under the relevant penalty provision, contending that the Assessing Officer and the CIT(A) erred in imposing the penalty.

10. The C.I.T.-I, Aaykar Bhawan, Indore vs S.Kumar Tyres Manufacturing Co. Ltd

Bench: Madhya Pradesh High Court
Date: 4 November 2022
Sections engaged: 271(1), 148
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal before the Madhya Pradesh High Court (Income Tax Appeal No. 142 of 2003) was filed by the Commissioner of Income Tax challenging the ITAT order dated 30.04.2003 in ITA Nos. 284/IND/02 and 339/IND/02 for Assessment Year 1992-93; per the source preview, the appeal was heard as a Section 260-A appeal, and the underlying dispute involved issues of addition that had previously been confirmed at the CIT(A) stage before the matter reached the Tribunal and then the High Court.

11. DCIT Cc7 (2), Mumbai vs M/S. Anik Industries Ltd, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 29 July 2022
Sections engaged: 271(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The revenue filed appeal (ITA No. 2267/Mum/2021) for Assessment Year 2004-05 against the CIT(A)'s order under the penalty provision; per the source preview, the revenue's grievance included whether the CIT(A) erred in holding that the addition made by the Assessing Officer in respect of waiver of loan treated as taxable did not amount to concealment, with the revenue contending the assessee had failed to give a bonafide explanation.

12. The Prajatantra Prachar Samity vs ACIT, Circle-2(1), Cuttack

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 2 June 2022
Sections engaged: 271(1), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 78 to 80/CTK/2009) cover Assessment Years 1985-86, 1989-90, and 1993-94 and were filed by the assessee against the consolidated CIT(A) order dated 28.11.2008; per the source preview, the assessee's representative submitted before the Bench that the quantum additions forming the basis of the penalty had been deleted by a Co-ordinate Bench of the Tribunal in ITA Nos. 38 to 40/CTK/2007 dated 27.05.2022, and that accordingly the penalty was liable to be reconsidered.

Patterns across these 12 rulings

Penalty linked to quantum addition outcome. More than one case in this set — including the Prajatantra Prachar Samity matter and the Hydro Engineering College matter — shows the recurring pattern where the penalty proceeding is directly consequential to the quantum assessment. Where the underlying addition is deleted or reduced at the appellate stage, the penalty becomes a follow-on issue.
NFAC as the intermediate appellate forum. Several appeals in this compilation (Drillcon, Mohini Chandnani Charitable, Khomram Chandrawanshi HUF, Ishtiaq Ahmad Rather) arise out of orders passed by the National Faceless Appeal Centre, reflecting the operational centrality of the NFAC layer in the current appellate chain for penalty matters.
Delay condonation as a threshold issue. The Mohini Chandnani Charitable case illustrates that procedural maintainability — specifically the condonation of delay in filing an appeal against a penalty order — can be a distinct preliminary issue that the Tribunal must resolve before reaching the merits of the penalty challenge.
Long-pendency penalty disputes. The Prajatantra Prachar Samity case (assessment years 1985-86, 1989-90, 1993-94, appealed in 2009 and decided in 2022) and the S. Kumar Tyres matter (assessment year 1992-93, High Court appeal decided in 2022) illustrate that Section 271(1) penalty litigation can remain unresolved across decades, particularly where linked quantum matters are also in dispute.
Multi-year and bundled appeals. Several cases in this set involve multiple assessment years heard together — Kulandaivel Selvam (four AYs), Prajatantra Prachar Samity (three AYs), Chaitanya Kochar (two AYs), Ishtiaq Ahmad Rather (two ITA numbers) — indicating that bundling of penalty appeals across years is a standard procedural feature of Section 271(1) litigation.

How to use this compilation

This index is a starting-point retrieval tool, not a substitute for full-text legal research. Each entry above reproduces only the identity fields and a brief procedural summary derived from the available source preview. The full text of every order — including the complete facts, rival contentions, legal analysis, and operative order — must be retrieved and read before any reliance is placed on the ruling. Orders can be accessed through indiankanoon.org, the official ITAT e-filing portal, and relevant High Court cause-list portals.

Researchers should also verify whether any order indexed here has been subsequently stayed, reversed, modified, or remanded by a higher forum. ITAT orders are subject to appeal before the jurisdictional High Court under Section 260A of the Income-tax Act, 1961, and High Court decisions are subject to further challenge before the Supreme Court. An order that appears final at the tribunal level may have been disturbed at a higher appellate stage after the date of this compilation. Checking for subsequent appellate history is an essential step before treating any indexed ruling as settled precedent.

Finally, for matters involving penalty in the context of assessment or reassessment, researchers should cross-check the relevant CBDT circulars, instructions, and Finance Act amendments that may affect the applicable penalty framework for the assessment year in question, since the penalty provisions and their thresholds have been amended at various points in legislative history.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 271(1) Penalty: 12 ITAT and HC Rulings Indexed (2022–2026)