2026 (5) TMI 1778

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.... following grounds of appeal: - "1. The Ld. CIT(A) NFAC, erred on facts and in law in upholding the penalty of Rs. 20,000/- u/s 272A(1)(d) of I. T. Act without appreciating that there was a reasonable cause being medical reason for non-compliance of the notices. 2. The Ld. CIT(A) failed to appreciate that due acute depression compliance could not be made during assessment proceeding, thus there was a reasonable cause for non-compliance of notices being medical reason. 3. The Ld. CIT(A) failed to appreciate that the assessment order passed u/s 147 r.w.s 144 of the IT Act, 1961 for the year under consideration dated 24.01.2025 has been set aside by Ld. CIT(A) NFA vide order dated 26.11.2025 hence the penalty upheld ....

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....ing on merits. 5. The facts giving rise to the present appeal are that the assessee did not file the return of income under section 139(1) of the Income Tax Act, 1961 ("Act", for short) for A.Y. 2019-20. During the course of assessment proceedings, notices u/s 142(1) of the Act were issued on 10.05.2024 and 22.10.2024; however, there was no compliance on the part of the assessee. Consequently, the Assessing Officer ("AO", for short) initiated penalty proceedings u/s 272A(1)(d) of the Act for failure to comply with the said notices and imposed the impugned penalty of Rs. 20,000/- vide order dated 18.07.2025. Aggrieved against this, the assessee preferred appeal before the Ld. CIT(A) who after considering the submissions, sustained the ....