2026 (7) TMI 688

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....ondent : Ms. P. Sunanda, JCIT ORDER PER MANU KUMAR GIRI, JM: The captioned appeal filed by the Assessee is directed against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi, [hereinafter referred to as "CIT(A)"] dated 21.08.2025 for Assessment Year 2020-21. 2. The Appellant filed her return of income u/s. 139 for the Assessment Year (A.Y.) 2021-22, declaring a total i....

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....appellate proceedings, the appellant failed to respond the notice issued without any reasons. Consequently, the penalty made by the Assessing Officer was confirmed. Now, the assessee is in appeal before this Tribunal. 4. Before us, the ld. Authorised Representative (AR) argued that the Ld.CIT(A) erred in upholding the assessment order without appreciating the sufficient cause of failure to comp....

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....vable property. The AO, treating the assessee's failure to comply with both notices as separate defaults, levied a penalty of Rs. 20,000/- u/s. 272A(1)(d), which came to be confirmed by the ld.CIT(A). On a careful consideration of the record, we notice that the assessee appeared before the AO on 23.10.2024 and sought an adjournment. The subsequent appearance of the assessee before the AO indic....

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....planation demonstrating reasonable cause for the continued non-compliance. Mere subsequent appearance before the AO seeking adjournment, without explaining the failure to comply with the second statutory notice, cannot by itself absolve the assessee from the consequences contemplated u/s. 272A(1)(d). In the absence of any cogent or convincing explanation, the default relating to the notice dated 0....