This compilation indexes 12 income-tax rulings — 10 from the Income Tax Appellate Tribunal (ITAT) and 2 from the Karnataka High Court — in which Section 271(1)(b) of the Income Tax Act, 1961 was engaged. The rulings span August 2025 to September 2026 and arise from diverse forums including Jodhpur, Delhi, Ahmedabad, Varanasi, Hyderabad, Chennai, Bangalore, Indore, and Bengaluru. The index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured reference to recent tribunal and court activity on this penalty provision.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers must verify all rulings against the full text of the original judgment and consult qualified advisors before acting on any information contained here.

The statutory framework in one paragraph

Section 271(1)(b) of the Income Tax Act, 1961 empowers the Assessing Officer to levy a penalty where an assessee fails to comply with a notice issued under the Act requiring the assessee to produce accounts, documents, or information, or to attend or otherwise comply with any direction. The penalty under this clause may be levied in the course of assessment or other proceedings where such non-compliance is established. The section operates alongside related provisions governing assessments, reassessments, and the broader penalty framework under Chapter XXI of the Act.

The 12 rulings

1. Ankit Agarwal,Churu vs ITO Ward-1, Churu

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 3 September 2026
Sections engaged: 132, 142(1), 143(2), 143(3), 147, 148, 151, 153C, 250, 271(1)(b), 271(1)(c), 68
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before ITAT Jodhpur (ITA No. 8/Jodh/2023) against the order dated 17.11.2022 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi, under section 250 of the Act, for Assessment Year 2015-16. The CIT(A) had dismissed the appeal preferred against the assessment order dated 26.11.2018 passed by the Income-tax Officer, Ward-1, Churu, under section 143(3) read with section 147 of the Act, determining the total income of the assessee at Rs. 43,80,740/-.

2. Rakesh Shukla,Delhi vs Assessing Officer, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 3 September 2026
Sections engaged: 115B, 115W, 142, 143, 144, 147, 271(1)(b), 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1481/Del/2026) for Assessment Year 2015-16 arose from the CIT(A)'s appellate order dated 30.12.2025, which in turn arose from the penalty order dated 22.11.2023 passed by the Assessing Officer under section 271(1)(b) of the Act. The brief facts as recorded in the source preview indicate that the assessee did not file his return of income for the impugned assessment year, and the case was reopened by the Revenue by invoking the provisions of section 147 of the Act.

3. Baraiya Galaji Kalaji,Gandhinagar vs The ITO, Ward-1, Gandhinagar

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 3 September 2026
Sections engaged: 142(1), 144, 144B, 147, 148, 148A(d), 271(1)(b), 271(1)(c), 271F
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 2332 & 2333/Ahd/2026) were filed for Assessment Year 2015-16. As per the source preview, the Registry noted a delay of 42 days in filing both appeals; the assessee's counsel submitted that the assessee was suffering from poor health and lacked proper knowledge and understanding of legal and taxation matters. The Tribunal, considering the explanation furnished and the supporting affidavit, condoned the delay of 42 days in the interest of justice and proceeded to hear the appeals.

4. Subhash Chandra Yadav,Varanasi vs Income Tax Officer, NFAC, Delhi

Bench: Income Tax Appellate Tribunal - Varanasi
Date: 31 August 2026
Sections engaged: 115B, 142(1), 147, 148, 148A, 250, 271(1)(b), 44A, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA Nos. 227 & 228/VNS/2024) were filed by the assessee for Assessment Year 2015-16 against separate orders of the CIT(A), NFAC, both dated 22.05.2024, wherein the CIT(A) dismissed the assessee's appeals against an order passed under section 147 read with section 144 by the Assessing Officer on 20.03.2023, and also confirmed a penalty of Rs. 30,000/- levied under section 271(1)(b). The source preview records that, since the penalty arose from the assessment proceedings and the cases were heard together, both appeals were taken up for disposal together.

5. Primary Agriculture Cooperative vs ITO, Ward-1, Mahabubnagar

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 5 August 2026
Sections engaged: 271(1)(b), 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA Nos. 125 & 126/Hyd/2026) were filed by Primary Agricultural Cooperative Society Veldanda for Assessment Year 2016-17, feeling aggrieved by separate orders of the lower appellate authority. The source preview confirms the appeal was filed before the Hyderabad 'A' Bench and was heard on 30.07.2026, with pronouncement on 05.08.2026; the substantive grounds are not further detailed in the available preview.

6. The Tamil Nadu Dr Ambedkar Law vs Income Tax Officer (Exemptions) - Ward

Bench: Income Tax Appellate Tribunal - Chennai
Date: 4 August 2026
Sections engaged: 271(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 4139/Chny/2025) for Assessment Year 2013-14 was filed by the Tamilnadu Dr. Ambedkar Law University against the order dated 31.10.2025 passed by the Commissioner of Income Tax (Appeals). The source preview confirms the appeal was before the 'B' Bench, Chennai, and was heard on 09.07.2026 with pronouncement on 04.08.2026; further substantive grounds are not detailed in the available source preview.

7. Madhvi Rameshbhai Bavlecha,Bhavnagar vs The ITO, Ward-1(8), Bhavnagar

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 17 July 2026
Sections engaged: 147, 148, 271(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2372/Ahd/2025) for Assessment Year 2013-14 was placed before the SMC Bench, Ahmedabad. As per the source preview, the assessee raised grounds asserting that both the Assessing Officer and the CIT(A) erred in passing impugned orders without properly appreciating the facts, submissions, and documentary evidence on record, and that such action was in gross violation of the principles of natural justice. The assessee also challenged the CIT(A)'s confirmation of the initiation of penalty proceedings.

8. Excel Hyde Park Ventures Private vs ACIT, Circle-2(2)(1), Bengaluru

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 15 July 2026
Sections engaged: 271(1)(b), 142(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 681/Bang/2026) for Assessment Year 2016-17 was filed against the order dated 24.12.2025 passed under section 250 of the Act by the CIT(A), National Faceless Appeal Centre, Delhi, which in turn arose from a penalty order under section 271(1)(b) of the Act. The source preview records that the solitary grievance of the assessee was against the penalty of Rs. 20,000/- levied under section 271(1)(b) for non-compliance of statutory notices issued under section 142(1) of the Act.

9. Sangeetha Velmurugan,Chennai vs ITO Non Corp Circle 19(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 13 July 2026
Sections engaged: 271(1)(b), 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 446/CHNY/2026) was filed by the assessee, an individual, against the order of the CIT(A)/National Faceless Appeal Centre, Delhi, passed under section 250 of the Act dated 04.12.2025, for Assessment Year 2016-17. The source preview confirms the appeal was before the 'C' Bench, Chennai, with hearing concluded on 09.07.2026 and pronouncement on 13.07.2026; further substantive details beyond the appellate posture are not available in the source preview.

10. Vidit Garg,Indore vs Assessing Officer, Gwalior

Bench: Income Tax Appellate Tribunal - Indore
Date: 6 July 2026
Sections engaged: 142, 271(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue filed appeals (ITA Nos. 586 to 592/Ind/2026) covering Assessment Years 2015-16 to 2021-22. As per the source preview, an assessment order under section 153C read with section 144 of the Act was passed on 30.03.2023 by the Dy. Commissioner of Income Tax (Central)-Gwalior, computing assessed income at Rs. 4,41,260/- for AY 2015-16. The preview further records that the consolidated assessment order noted that questionnaires under section 142 for AY 2015-16 to 2021-22 were issued, providing the factual context for the penalty engagement.

11. Sri Reddy Bayappa Y vs Income Tax Officer

Bench: Karnataka High Court
Date: 12 December 2025
Sections engaged: 148A(b), 147, 271(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 21373 of 2025) was filed before the Karnataka High Court at Bengaluru under Articles 226 and 227 of the Constitution of India, praying for a writ of certiorari or direction in the nature of a writ of certiorari quashing the notice under section 148A(b) of the Act dated 29.03.2023 (issued on 31.03.2023) without a DIN number, issued by respondent no. 2. The petition was heard at the Karnataka High Court with section 271(1)(b) among the provisions cited in the matter.

12. Sri Muralidhara Krishnappa vs Income Tax Officer

Bench: Karnataka High Court
Date: 14 August 2025
Sections engaged: 148A, 271(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP No. 22643 of 2025) was filed before the Karnataka High Court at Bengaluru, with the petitioner represented through an SPA holder. The petition engaged section 148A alongside section 271(1)(b) of the Act; the source preview confirms the matter was before the Karnataka High Court and lists multiple income tax officer respondents including the Principal Commissioner of Income Tax and the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes.

Patterns across these 12 rulings

Section 271(1)(b) consistently arises as a downstream consequence of reassessment proceedings. In multiple cases — including cases 2, 4, 7, and 11 — the penalty under section 271(1)(b) was levied in the context of proceedings initiated under sections 147 and 148, suggesting that reassessment-linked non-compliance is a recurring trigger for this penalty provision.
The National Faceless Appeal Centre (NFAC) route is uniformly present at the first appellate stage. Cases 1, 2, 4, 8, and 9 all reflect the standard appellate chain in which the CIT(A) at NFAC, Delhi, decided the first appeal before the matter reached the ITAT, reflecting the current faceless regime's operational footprint in penalty litigation.
Multiple assessment years are sometimes consolidated in a single appeal proceeding. Case 10 (Vidit Garg) covers Assessment Years 2015-16 to 2021-22 in a single set of appeals (ITA Nos. 586 to 592/Ind/2026), indicating that where the underlying non-compliance spans several years, penalty proceedings and the resulting appeals may similarly be clubbed and heard together.
Delay condonation at the appellate stage is a preliminary procedural issue in penalty appeals. Case 3 (Baraiya Galaji Kalaji) illustrates that applications for condonation of delay in filing the appeal — supported by affidavits citing health or lack of legal knowledge — are a distinct preliminary step that tribunals address before proceeding to the merits of the section 271(1)(b) challenge.
Both ITAT benches and the High Court (writ jurisdiction) are engaged by taxpayers contesting section 271(1)(b) matters. Cases 11 and 12 demonstrate that, where notices forming the foundation of penalty proceedings are themselves challenged, taxpayers approach the High Court under Articles 226 and 227 of the Constitution, rather than the ITAT, reflecting the constitutional writ route as an avenue distinct from the statutory appellate path.

How to use this compilation

This compilation is a structured index and should be treated as a starting point for legal research, not as a substitute for the full text of any judgment. Each ruling listed here should be verified against the complete order as published on indiankanoon.org or the official court portal before it is cited, relied upon, or referred to in any pleading, submission, or advice note. The source previews on which the procedural summaries above are based are extracts only; substantive holdings, relief granted, and detailed reasoning are contained in the full orders.

Researchers should check whether any ruling listed here has been stayed, appealed to a higher forum, or reversed subsequent to its date of pronouncement. Tribunal orders may be appealed to the relevant High Court, and High Court orders may be subject to Special Leave Petitions before the Supreme Court of India. The absence of a reversal note in this index does not confirm that a ruling remains good law.

Finally, practitioners should check for any CBDT circulars, instructions, or notifications issued after the date of a ruling that may affect the interpretation or application of section 271(1)(b) in the context of a specific client matter. The statutory framework and penalty thresholds may also be subject to amendment by Finance Acts subsequent to the dates of the rulings indexed here.

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)(b) Penalty: 12 ITAT and HC Rulings (2025–2026)