This compilation presents twelve recent tribunal and High Court rulings—pronounced between January 2026 and July 2026—in which Section 271D of the Income Tax Act, 1961 was directly engaged. The index spans ITAT benches at Delhi, Chennai, Bangalore, Rajkot, Cuttack, Vizag, and Pune, as well as the Telangana High Court. It is intended as a structured reference point for in-house tax teams, Big-4 associates, and law firm researchers who need to survey the current litigation landscape around Section 271D penalty proceedings efficiently.

Research index only. This page is a factual compilation of publicly available court and tribunal orders for research and reference purposes. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers should consult the full text of each judgment and seek qualified professional counsel before acting on any information.

The statutory framework in one paragraph

Section 271D of the Income Tax Act, 1961 provides that if a person takes or accepts any loan or deposit in contravention of the provisions of Section 269SS (which prohibits acceptance of loans or deposits of ₹20,000 or more otherwise than by account-payee cheque, account-payee bank draft, or electronic clearing system), the Joint Commissioner of Income Tax is empowered to direct that such person shall pay, by way of penalty, a sum equal to the amount of the loan or deposit so taken or accepted. The section thus operates as a strict-liability penalty provision linked to the mode-of-payment mandate in Section 269SS, and the proceedings under Section 271D are required to be initiated and conducted in accordance with the procedural safeguards prescribed in Section 274 of the Act.

The 12 rulings

1. DCIT, Central Circle-3, New Delhi, New vs Tarun Gupta, East Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 15 July 2026
Sections engaged: 271D, 269S
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the Revenue before the Income Tax Appellate Tribunal, Delhi (ITA 8591/DEL/2025) and is directed against the order of the Commissioner of Income Tax (Appeals)-30, New Delhi, dated 25.09.2025, which itself arose out of a Penalty Order dated 26.07.2024 passed by the Additional Commissioner of Income Tax, Central Range-1, New Delhi, under Section 271D of the Act for Assessment Year 2019-20. The source preview confirms the proceeding is a Revenue appeal challenging a CIT(A) order in a Section 271D penalty matter for AY 2019-20; substantive findings are not available in the source preview.

2. Natarajan Sayikumar, Tiruvannamalai vs ITO Ward 1, Tiruvannamalai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 8 July 2026
Sections engaged: 269S, 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 352/Chny/2026) was filed by the assessee before the Chennai bench against the order dated 09.01.2026 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for Assessment Year 2015-16. The source preview records that the assessee is an individual who had no taxable income and had not filed a return of income for AY 2015-16, and that the Assessing Officer found that during the relevant year the assessee had deposited cash of Rs. 64,60,000/- into his bank account; the penalty proceedings appear to have followed from those findings, with the ultimate disposition not stated in the available preview.

3. Kodiambadi Subrahmanya Rai, Mysuru vs Addl.CIT (Central Range)-3 Blr

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 8 July 2026
Sections engaged: 271D, 275(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter comprised four consolidated appeals (ITA Nos. 2814, 2815, 2816 & 2817/Bang/2025) covering Assessment Years 2016-17, 2017-18, 2018-19, and 2020-21, all pertaining to the same assessee and involving similar issues arising from a similar factual matrix; the bench heard them together and decided them by way of a consolidated order, treating the assessee's appeal for AY 2016-17 as the lead case with the decision applying mutatis mutandis to the remaining appeals. The source preview indicates that Section 271D and Section 275(1)(c) were the sections engaged, but the substantive findings and final direction are not disclosed in the available preview.

4. Velji Parsotambhai Gohel, Rajkot vs Income Tax Officer, Ward-1(2)(1)

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 29 June 2026
Sections engaged: 271D, 269S
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 283/Rjt/2026) was filed by the assessee and pertains to Assessment Year 2018-19; it is directed against the order passed under Section 250 of the Act by the National Faceless Appeal Centre (NFAC), Delhi / Commissioner of Income-tax (Appeals), dated 10.12.2025, which in turn arose out of a penalty order passed by the Assessing Officer under Section 271D of the Act. The ultimate disposition of the appeal is not specified in the available source preview.

5. Income Tax Officer Ward 48(1), New Delhi vs Wahid Ali, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 29 June 2026
Sections engaged: 269S, 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter is a Miscellaneous Application (M.A. No. 311/Del/2024, arising out of ITA No. 1916/Del/2022) for Assessment Year 2017-18, filed by the Revenue seeking to recall or rectify the tribunal's earlier order dated 08.01.2024, which had allowed the Revenue's main appeal on merits and deleted a penalty of Rs. 28,13,000/- under Section 271D of the Act. The source preview records that the miscellaneous application was heard and that the impugned order of 08.01.2024 had deleted the Section 271D penalty upon a detailed discussion, but the outcome of the miscellaneous application itself is not specified in the available preview.

6. Octagon Nirman Private vs Income Tax Officer, ITO, Ward Bargarh

Bench: Income Tax Appellate Tribunal - Cuttack
Date: 29 June 2026
Sections engaged: 269S, 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 412/CTK/2026) was filed by the assessee against the order of the NFAC, Delhi dated 17.02.2026 passed under Section 250 of the Act for Assessment Year 2013-14; the source preview records that the NFAC had dismissed the assessee's appeal, upholding the penalty order dated 27.09.2022, and that the learned counsel for the assessee submitted that the Assessing Officer had invoked the provisions of Section 271D of the Act. The final direction of the ITAT in the present appeal is not specified in the available source preview.

7. Shree Agrawal Logistics, Gandhidham vs The ITO Ward 2 Gandhidham, Gandhidham

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 25 June 2026
Sections engaged: 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 607/RJT/2026) relates to Assessment Year 2017-18; the source preview records that the case was originally selected for scrutiny and assessment was completed accepting the returned income, followed by a rectification order determining total income at Rs. 22,508/-, and that penalty proceedings under Section 271D were thereafter initiated. The substantive findings and the final direction of the tribunal are not disclosed in the available preview.

8. Manish Narendrabhai Gandhi, Rajkot vs Addl.CIT, Range-1(1), Rajkot, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 12 June 2026
Sections engaged: 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter comprised two appeals (ITA Nos. 596 & 597/RJT/2026) for Assessment Year 2015-16; the source preview sets out a tabulated list of party names and corresponding transaction amounts (totalling Rs. 10,08,000/- and Rs. 4,70,000/- across two sets of related parties), indicating that the Section 271D penalty proceedings involved alleged cash receipts from or among family/HUF members. The substantive findings and the outcome of the appeals are not disclosed in the available preview.

9. Lakshmana Swamy vs Income Tax Officer, Ward-2(3)

Bench: Income Tax Appellate Tribunal - Vizag
Date: 24 April 2026
Sections engaged: 271D, 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 597/VIZ/2025) was filed by the assessee against the order dated 04.09.2025 passed by the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre, Delhi, for Assessment Year 2016-17; the source preview notes that the assessee's authorised representative prayed to take up a specific ground along with additional submissions. The substantive findings and the final direction of the tribunal are not disclosed in the available source preview.

10. Chandra Sekhar Gundapu, Krishna Lanka vs Income Tax Officer, Ward 2(1)

Bench: Income Tax Appellate Tribunal - Vizag
Date: 18 March 2026
Sections engaged: 271D, 269S
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 334/Viz/2025) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre, Delhi, dated 26.03.2025 for Assessment Year 2016-17, which arose out of the penalty order passed by the Assessing Officer under Section 271D of the Act dated 23.05.2023. The source preview confirms the assessee was aggrieved by the CIT(A) order, but the substantive findings and the tribunal's final direction are not disclosed in the available preview.

11. M/S.Meghana Avenues Private Limited vs The Commissioner Of Income Tax

Bench: Telangana High Court
Date: 5 March 2026
Sections engaged: 271D, 274
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 24403 of 2025) before the Telangana High Court raised the specific question of whether penalty proceedings under Section 271D of the Act can be initiated on satisfaction being recorded by the Joint Commissioner on perusal of assessment records, as opposed to by the Assessing Officer. The source preview records that the challenge was to the NFAC order dated 04.06.2025 for Assessment Year 2017-18, which upheld the penalty of Rs. 40,50,000/- imposed under Section 271D read with Section 274 of the Act by the National Faceless Assessment Centre order dated 19.10.2022; the court's final ruling on this question of initiating authority is not disclosed in the available preview.

12. DCIT, Central Circle-1, Aurangabad vs Smt. Asha Bhagwanrao Kadam, Pune

Bench: Income Tax Appellate Tribunal - Pune
Date: 19 January 2026
Sections engaged: 271D, 153A, 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: This consolidated matter covered multiple appeals — IT(SS)A Nos. 39 & 40/PUN/2024 (AY 2019-20), ITA Nos. 1894, 1895 & 1896/PUN/2024 (AYs 2019-20 and 2018-19), and ITA Nos. 607 to 611/PUN/2025 (AYs 2019-20 and 2018-19) — with appeals filed both by the Revenue and by the assessee. The co-occurrence of Section 271D alongside Section 153A and Section 143(3) in the sections engaged indicates the penalty proceedings arose in the context of search-related assessments; the substantive findings and final direction of the bench are not disclosed in the available source preview.

Patterns across these 12 rulings

Prevalence of NFAC-routed penalty disputes. Across multiple cases in this compilation — including Cases 2, 4, 6, 9, 10, and 11 — the immediate order under challenge before the tribunal or High Court is one passed by the National Faceless Appeal Centre (NFAC), Delhi. This reflects the operational reality that Section 271D penalty appeals at the first-appellate level are now routed through the faceless regime, making NFAC orders the common upstream trigger for ITAT proceedings.
Frequent pairing of Section 271D with Section 269S. Seven of the twelve cases (Cases 1, 2, 4, 5, 6, 10) list both Section 271D and Section 269S in their sections engaged. This is structurally expected, since a Section 271D penalty can only arise from a contravention of the mode-of-payment requirement, but the consistent pairing across geographically diverse benches confirms that both provisions remain active focal points in the same penalty proceedings.
Geographic spread of active Section 271D litigation. The twelve rulings span benches at Delhi, Chennai, Bangalore, Rajkot (multiple cases), Cuttack, Vizag (multiple cases), Pune, and the Telangana High Court. The concentration at Rajkot and Vizag across multiple orders within a short window suggests active local enforcement and appeal filing patterns in those jurisdictions.
Procedural authority as a live issue at High Court level. Case 11 (Meghana Avenues, Telangana High Court) specifically frames the dispute around the authority competent to initiate Section 271D penalty proceedings — whether satisfaction can be recorded by the Joint Commissioner on perusal of assessment records rather than by the Assessing Officer. This procedural question, reaching writ jurisdiction, indicates that initiation-of-proceedings challenges remain a distinct litigation strategy separate from the merits of the underlying transaction.
Consolidated hearing of multi-year penalty appeals. Cases 3 (four assessment years), 8 (two ITAs), and 12 (multiple ITAs across two assessment years filed by both parties) illustrate that Section 271D penalty disputes frequently arise across multiple assessment years for the same assessee and are disposed of by way of consolidated orders with a lead-case approach, which is a recurring procedural feature researchers should anticipate when tracing the full litigation chain for a given assessee.

How to use this compilation

This index is organised to support rapid identification of Section 271D penalty rulings by bench, date, and sections engaged. Each case entry should be treated as a research starting point, not a conclusive summary. The source previews available for this compilation are limited to the opening portions of the orders and, in every instance, do not disclose the tribunal's or court's final reasoning or operative direction. Before relying on any ruling for any purpose, researchers must obtain and read the full text of the judgment from official sources such as the Income Tax Appellate Tribunal's official website, the relevant High Court's official portal, or indiankanoon.org.

Researchers should also verify whether any order listed here has been subsequently stayed, appealed to a higher forum, or reversed. An ITAT order in favour of the assessee may be the subject of a pending High Court appeal by the Revenue, and vice versa. Where a matter involves a writ petition before a High Court, researchers should check for any interim stay orders, final disposal, or further appeal to the Supreme Court. The tax litigation chain in penalty matters often spans several years and multiple forums.

Finally, penalty proceedings under Section 271D may be accompanied by or sequenced after assessment orders, search-related proceedings, or rectification orders under other provisions. Researchers dealing with a specific set of facts should map the full procedural chain — from the original assessment or penalty order, through the first-appellate stage, to the tribunal or court — and cross-reference applicable CBDT circulars and instructions that may bear on the interpretation or applicability of the penalty provisions.

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 271D Penalty: 12 ITAT and HC Rulings Compiled (2026)