This compilation indexes twelve recent rulings — spanning multiple ITAT benches and two High Courts — in which Section 271 of the Income Tax Act, 1961 was one of the provisions engaged. The cases range from penalty levy disputes and condonation-of-delay petitions at the appellate stage to writ proceedings before High Courts. The index covers orders pronounced between April 2025 and August 2026 and is intended as a starting point for researchers tracking litigation trends around penalty provisions under the Act.

Research index only. This page is a structured case-law reference compiled for tax professionals, in-house counsel, and researchers. Nothing on this page constitutes legal or tax advice. Readers must verify every ruling against the full, authoritative judgment text before relying on it for any purpose.

The statutory framework in one paragraph

Section 271 of the Income Tax Act, 1961 empowers the Assessing Officer, the Commissioner (Appeals), or the Principal Commissioner or Commissioner to levy a monetary penalty on an assessee in specified circumstances, including where the assessee has concealed particulars of income or furnished inaccurate particulars of income (Section 271(1)(c)), failed to comply with notices or directions, or committed other defaults enumerated in the section. The quantum of penalty, the procedural safeguards (including the requirement to issue a show-cause notice under Section 274), and the defences available to an assessee are all governed by the text of Section 271 read with the associated provisions of the Act. The section has been the subject of extensive litigation on questions of initiation, jurisdiction, mens rea, and the link between the assessment order and the penalty proceedings.

The 12 rulings

1. Saint Xavier Educational & Charitable vs ITO (Exemption) Ward Bhubaneswar

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 20 August 2026
Sections engaged: 251, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before the ITAT Cuttack Bench (through hybrid hearing at Kolkata) in ITA No. 753/CTK/2026 against the order of the CIT(A), NFAC, Delhi in appeal no. NFAC/2018-19/10393062 dated 21.11.2025 for assessment year 2019-20. The appeal was delayed by 181 days, and the Tribunal considered and condoned the delay on the basis of the condonation petition filed by the assessee stating sufficient reasons.

2. Pradiptakumarpatel Raja Radhakanta vs Income Tax Officer, Sambalpur

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 19 August 2026
Sections engaged: 251, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: These are two appeals filed by the assessee in ITA Nos. 639 & 754/CTK/2026 against the orders of CIT(A), NFAC, Delhi in appeal nos. NFAC/2012-13/10125239 and NFAC/2013-14/10125243, both dated 29/05/2024, covering assessment years 2013-14 and 2014-15 respectively. The appeals were delayed by 686 and 731 days respectively, and the Tribunal condoned the said delays upon consideration of the petitions filed by the assessee stating sufficient reasons; notably, none appeared on behalf of the assessee at the hearing.

3. Asit Behera, Cuttack vs Income Tax Officer, Ward 1(1), Cuttack

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 18 August 2026
Sections engaged: 251, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee in ITA No. 666/CTK/2026 against the order of CIT(A), NFAC, Delhi in appeal no. NFAC/2017-18/10265879 dated 23/05/2025 for assessment year 2018-19. The appeal was delayed by 338 days; the assessee filed a condonation petition supported by an affidavit stating sufficient reasons, and the Tribunal condoned the delay of 338 days in filing the appeal.

4. Shri Durga Prasad Saraf Vidyapeeth vs I.T.O (Exemption), Cuttack, R Bhawan

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 17 August 2026
Sections engaged: 251, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: The two appeals in ITA Nos. 608 & 609/CTK/2026 covering assessment years 2022-23 and 2023-24 arose from the JCIT's dismissal of the assessee's earlier appeals solely on the ground of delays of 1033 days and 443 days respectively, without adjudication on merits, as the assessee had failed to present its case before the JCIT. Per the source preview, the Tribunal noted that when substantial justice is pitted against technical considerations, the former should prevail, and it admitted the appeals after considering the reasons submitted for the delays.

5. Deputy Commissioner Of Income Tax vs Jayapriya Company, Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 6 August 2026
Sections engaged: 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed ITA Nos. 1110 to 1113/Chny/2026 along with Cross Objections (CO Nos. 21 to 24/Chny/2026) covering assessment years 2013-14 to 2016-17. Per the source preview, the orders of assessment under Section 147 of the Act and notices under Section 274 read with Section 271(1)(c) of the Act were issued in March 2024 for all four assessment years; the assessee claimed that the Assessing Officer did not initiate the penalty proceedings in accordance with the prescribed procedure, which formed a ground before the Tribunal.

6. Smt. Priya vs Sri C M Mallegowda

Bench: Karnataka High Court
Date: 29 July 2026
Sections engaged: 138, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter is a criminal petition (CRL.P No. 7596 of 2019) filed under Section 482 of the Cr.P.C. before the Karnataka High Court at Bengaluru, praying to quash proceedings in C.C. No. 872/2018 on the file of the Senior Civil Judge and J.M.F.C., Tiptur, for an offence punishable under Section 138 of the Negotiable Instruments Act, 1881. While Section 271 of the Income Tax Act appears as a cited section in the source data, the source preview centres on NI Act Section 138 cheque-dishonour proceedings; accordingly, the substantive content of this ruling as available in the preview relates to those criminal proceedings rather than to an income-tax penalty matter.

7. Cognizant Technology Solutions vs Assistant Commissioner Of Income Tax

Bench: Madras High Court
Date: 6 July 2026
Sections engaged: 271, 220
Outcome: Outcome not specified in source
Procedural / substantive ground: Cognizant Technology Solutions India Private Limited filed a batch of Writ Petitions (WP Nos. 25670, 25689, 25692, 25696, 26308, 26313 & 26317 of 2026) under Article 226 of the Constitution of India before the Madras High Court. Per the source preview, the common prayer in four of the writ petitions was for a Writ of Certiorarified Mandamus to quash the impugned order bearing DIN ITBA/COM/F/17/2026-27/1089431756(1) dated 05.06.2026 for AY 2015-16, AY 2016-17, AY 2017-18 and AY 2018-19, and to direct the respondent not to initiate any recovery proceedings for those assessment years.

8. Bariath Pacs Ichak, Hazaribagh vs ITO, Ward 1(2), Hazaribagh

Bench: Income Tax Appellate Tribunal - Ranchi
Date: 25 March 2026
Sections engaged: 69A, 271
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 432/RAN/2024 was filed by the assessee against the order of the CIT(A) dated 25.07.2023 for assessment year 2017-18. Per the source preview, the assessment order was passed under Section 147/143(3) of the Act dated 17.12.2019, wherein the Assessing Officer added a sum of Rs. 42,09,370/- under Section 69A read with Section 115BBE of the Act on the ground that the source of cash deposits made by the assessee in its bank account remained unexplained.

9. Omshree Agrotech Private vs Assessment Unit, ITD, NFAC, Delhi

Bench: Income Tax Appellate Tribunal - Pune
Date: 25 March 2026
Sections engaged: 271, 153A
Outcome: Outcome not specified in source
Procedural / substantive ground: Three appeals in ITA Nos. 2189 to 2191/PUN/2024 at the instance of the assessee, pertaining to assessment years 2009-10, 2011-12 and 2012-13, were directed against separate orders dated 26.08.2024 framed by CIT(A), Pune-11 arising out of penalty orders. Per the source preview, the common issue raised in all three appeals is against the levy of penalty, and a search and seizure action was conducted on the Omshree Group cases of Dhule on 20.11.2013, of which the assessee was a part.

10. Assistant Commissioner Of Income Tax vs Sri Maheswary Granites (P) Ltd

Bench: Income Tax Appellate Tribunal - Chennai
Date: 20 February 2026
Sections engaged: 271, 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue's appeal in ITA No. 3054/CHNY/2025 before the ITAT Chennai 'D' Bench was directed against the order of the Commissioner of Income Tax (Appeals), Chennai-20, dated 26.08.2025 passed under Section 250 of the Act for assessment year 2015-16. Per the source preview, one of the grounds raised by the department was that the CIT(A) erred in deleting a penalty of Rs. 69,71,783/- levied under Section 271AAB(1)(c) of the Act, and the department contended that the CIT(A)'s order was erroneous on facts and in law.

11. Dinesh Kumar S/O Pukhraj Aged About vs National Faceless Appeal Centre

Bench: Andhra Pradesh High Court - Amravati
Date: 20 January 2026
Sections engaged: 271
Outcome: Outcome not specified in source
Procedural / substantive ground: Writ Petition No. 32860 of 2025 was filed under Article 226 of the Constitution of India before the High Court of Andhra Pradesh at Amaravati by M/s J.R. Jewellers Private Limited, Vijayawada, represented by its Proprietor Sri Dinesh Kumar S/o Pukhraj. Per the source preview, the petition prayed for an appropriate writ, order or direction in the nature of a Writ of Mandamus declaring the levy of penalty to be unlawful, with the National Faceless Appeal Centre and the Assistant Commissioner of Income Tax among the named respondents.

12. Jomon John, Bazar vs I. T. O, Ward 2, Alappuzha

Bench: Income Tax Appellate Tribunal - Cochin
Date: 29 April 2025
Sections engaged: 272A(1), 271
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 578/Coch/2024 was filed by the assessee against the order of the CIT(A)/NFAC dated 28.05.2024 for assessment year 2017-18. Per the source preview, the scrutiny assessment was completed on 30/12/2019, and during the course of assessment proceedings, the assessee failed to comply with a notice under Section 142(1) of the Act dated 12/02/2019; a notice under Section 274 read with Section 272A(1)(d) of the Act dated 26.10.2019 was accordingly issued, with which the assessee also failed to comply.

Patterns across these 12 rulings

Condonation of delay as a recurring threshold issue. Cases 1 through 4 (Saint Xavier Educational, Pradiptakumarpatel Raja Radhakanta, Asit Behera, and Shri Durga Prasad Saraf Vidyapeeth) all involved substantial delays — ranging from 181 days to over 1,000 days — in filing appeals before the Tribunal. In each instance, the ITAT Cuttack Bench considered condonation petitions and dealt with the tension between procedural timelines and the principle that substantial justice should prevail over technicalities.
NFAC orders as the immediate subject of ITAT challenge. Across multiple cases in this compilation (Cases 1, 2, 3, 9, and 12), the appellate order immediately challenged before the ITAT was one passed by the CIT(A) sitting within the National Faceless Appeal Centre (NFAC), Delhi, reflecting the operationalisation of the faceless appeals regime as a structural feature of the current litigation landscape.
Section 271 appearing alongside a wide range of co-provisions. The rulings in this index show Section 271 being cited alongside diverse provisions: Section 153A (search-related assessments, Case 9), Section 69A (unexplained cash deposits, Case 8), Section 274 (procedural notice, Cases 10 and 12), and Section 272A(1) (failure to comply with notices, Case 12). This illustrates that Section 271 litigation rarely arises in isolation and is typically embedded in broader factual and procedural contexts.
Revenue-initiated appeals on penalty deletion. Case 5 (DCIT vs Jayapriya Company) and Case 10 (ACIT vs Sri Maheswary Granites) both involve the Revenue as the appellant challenging a lower appellate authority's deletion or adverse treatment of a penalty levy, indicating that departmental appeals against penalty relief granted at the CIT(A) stage form a significant subset of Section 271-related ITAT litigation.
High Court writ jurisdiction invoked alongside Section 271. Cases 7 (Cognizant Technology Solutions before the Madras High Court) and 11 (Dinesh Kumar before the Andhra Pradesh High Court) demonstrate that Section 271-related matters are not confined to the ITAT appellate track; parties have approached High Courts under Article 226 of the Constitution, seeking writs in connection with penalty orders and related proceedings, reflecting the breadth of the section's litigation footprint.

How to use this compilation

This index is designed as a research starting point, not a definitive legal authority. Each entry above is derived from structured metadata and order previews in the TaxNoticeAI corpus. Before relying on any ruling for any purpose — whether for case strategy, academic analysis, or professional opinion — the researcher should obtain and read the full text of the judgment from the official court portal (such as indiankanoon.org, the ITAT e-filing portal, or the relevant High Court website) and verify that the order has not been subsequently stayed, reversed, modified on appeal, or rendered infructuous by a settlement or withdrawal.

Researchers should also check whether the legal position established in any ruling has been affected by subsequent legislative amendments to the Income Tax Act, 1961, or by CBDT circulars, instructions, and notifications issued after the date of the order. Section 271 has undergone significant statutory changes over the years, and the applicable version of the provision will depend on the assessment year in question in any given case.

Finally, practitioners working with these rulings should verify bench composition, ITA numbers, and PAN details against the official court record, since the source previews in this index may be truncated and may not capture all relevant procedural facts, including any remand directions, part-hearings, or interim orders that preceded the final pronouncement.

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 Penalty: 12 Recent ITAT and High Court Rulings (2025–2026)