This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders, pronounced between June and August 2026, in which Section 273B of the Income Tax Act, 1961 was among the sections cited. Section 273B provides a statutory defence against certain penalties where the assessee can demonstrate that the failure was owing to a reasonable cause. The rulings span multiple benches — Delhi, Chandigarh, Chennai, and Lucknow — and arise in the context of a variety of underlying penalty proceedings, including those relating to tax-audit defaults, acceptance of loans in cash, and non-compliance with notices. This index is designed for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, citation-ready reference point before consulting the full text of each judgment.

Research index only. This page catalogues publicly available ITAT orders for reference purposes. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers must consult the full text of each judgment and seek independent professional advice before acting on any matter.

The statutory framework in one paragraph

Section 273B of the Income Tax Act, 1961 provides that, notwithstanding anything contained in the provisions specified therein (which include, among others, sections 271B, 271D, 271E, and 272A), no penalty shall be imposed on an assessee for any failure referred to in those provisions if the assessee proves that there was reasonable cause for the said failure. The section functions as a general saving provision and places the burden on the assessee to affirmatively establish that the failure was not owing to neglect, default, or deliberate conduct but to circumstances beyond reasonable control. The precise scope of "reasonable cause" is a question of fact determined on the facts and circumstances of each case by the adjudicating authority.

The 12 rulings

1. D B Engineering P. Ltd.,Delhi vs ACIT Circle 7(1), Delhi, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 6 August 2026
Sections engaged: 139(1), 147, 250, 271B, 273B, 274, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed against a penalty proceeding in which a notice under Section 274 read with Section 271B was issued to the assessee company, alleging failure to get accounts audited or to furnish the required audit report. Per the source preview, the assessment had been completed and a penalty of Rs. 1,50,000/- was imposed on the assessee for the alleged default; the assessee's reply was not found acceptable by the Revenue authorities. The appeal (ITA No. 425/Del/2026 for A.Y. 2016-17) was heard on 12 May 2026 and pronounced on 6 August 2026 before the Delhi Bench.

2. Tarun Sharma, Yamunanagar,Yamuna vs Jao The Income Tax Officer Ward-5

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 3 August 2026
Sections engaged: 269S, 271D, 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 211/CHANDI/2026 and 212/CHANDI/2026) challenged the confirmation of penalty under Section 271D for Assessment Years 2011-12 and 2012-13. Per the source preview, the CIT(A) had confirmed a penalty of Rs. 7.90 Lacs as levied by the Assessing Officer, arising from an assessment framed to verify sources of cash deposits of Rs. 17.02 Lacs; the assessee had obtained short-term loans from different persons, which gave rise to the penalty proceedings. The matter was heard on 14 July 2026 and pronounced on 3 August 2026.

3. Badmanaban Narayanan,Kancheepuram vs ITO Ward 1, Kancheepuram

Bench: Income Tax Appellate Tribunal - Chennai
Date: 21 July 2026
Sections engaged: 269S, 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 456/CHNY/2026 for Assessment Year 2017-18) was filed by the assessee against an order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, passed under Section 250 of the Act, dated 05.01.2026. The hearing concluded on 13 July 2026 and the order was pronounced on 21 July 2026. The source preview is procedural in nature and does not disclose the substantive holding in the available extract.

4. Partyaksh Sharma,Faridabad vs ITO Ward 28(1), New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 July 2026
Sections engaged: 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: A preliminary issue addressed in this appeal (ITA No. 1813/DEL/2026 for Assessment Year 2017-18) was condonation of delay: the ITAT Registry reported the appeal as time-barred by 173 days. Per the source preview, the assessee filed an affidavit explaining that a new tax consultant discovered the order upon reviewing records on the Income Tax Portal and, upon learning no appeal had been filed, the appellant promptly filed before the ITAT, resulting in the approximate 173-day delay. The matter was heard on 13 July 2026 and pronounced on 17 July 2026.

5. 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: This appeal (ITA No. 446/CHNY/2026) was filed by the assessee against the order of the CIT(A)/NFAC, Delhi dated 04.12.2025 for Assessment Year 2016-17. The assessee is described as an individual in the source preview. The appeal was heard on 9 July 2026 and pronounced on 13 July 2026; the available extract does not disclose the substantive findings beyond the procedural framing.

6. Tsc Fashions Pvt. Ltd.,Tiruppur vs ITO, Ward-2(1), Tiruppur

Bench: Income Tax Appellate Tribunal - Chennai
Date: 1 July 2026
Sections engaged: 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: Four appeals (ITA Nos. 147, 148, 149 & 150/Chny/2026) were filed by the assessee against CIT(A)/NFAC orders dated 27.11.2025 (penalty matters for Assessment Years 2012-13, 2013-14 & 2014-15) and 10.12.2025 (quantum matter for Assessment Year 2013-14). Per the source preview, the assessee contended that the audit report could not be furnished due to circumstances it sought to explain, and no authorised representative appeared on behalf of the appellant at the hearing on 5 May 2026. The order was pronounced on 1 July 2026.

7. Maiam Global Foods Ltd.,Chennai vs ITO, Corporate Circle-4(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 1 July 2026
Sections engaged: 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 3947/Chny/2025 for Assessment Year 2016-17) was directed against the CIT(A)/NFAC order dated 28.10.2025. Per the source preview, the CIT(A) had confirmed a penalty of Rs. 1,50,000/- levied by the Assessing Officer. The matter was heard on 6 May 2026 and pronounced on 1 July 2026; the available extract does not set out the tribunal's substantive findings in the text preview portion.

8. Amar Liquors,Lucknow vs DCIT/ACIT-3, Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 30 June 2026
Sections engaged: 272A(1)(d), 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 741/LKW/2025 for Assessment Year 2022-23) challenged the CIT(A)'s confirmation of a penalty. Per the source preview, the assessee contended that the CIT(A) failed to appreciate the submissions explaining the facts and circumstances causing non-compliance of notices before the Assessment Unit, and further that the CIT(A) was not justified in confirming a penalty of Rs. 10,000 (out of Rs. 40,000/- levied by the Assessing Officer) on the ground that neither satisfaction was recorded in the Assessment Order nor was the matter reflected in the penalty show-cause notice. The appeal was heard on 4 June 2026 and pronounced on 30 June 2026.

9. Mariappan Rajendran,Thiruvarur vs The Income Tax Officer, Ward - 1

Bench: Income Tax Appellate Tribunal - Chennai
Date: 29 June 2026
Sections engaged: 273B, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA Nos. 2185 & 2192/Chny/2026) were preferred by the assessee against the CIT(A)/NFAC order dated 07.01.2026 for Assessment Year 2019-20. The assessee is identified as Mariappan Rajendran of Thiruvarur, Tamil Nadu. The hearing took place on 18 June 2026 and the order was pronounced on 29 June 2026; the source preview is largely procedural and does not disclose the substantive findings in the available extract.

10. Stargate Enterprises Pvt vs DCIT, Corp. Circle-3(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 25 June 2026
Sections engaged: 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1396/CHNY/2026 for Assessment Year 2018-19) was heard on 24 June 2026 and pronounced on 25 June 2026. Per the source preview, the assessee's representative argued that the income in question was not assessable under the head "Income from Business or Profession" and that tax audit under Section 44AB was therefore not applicable, making the levy of a penalty under Section 271B not tenable; Section 273B was among the provisions cited in the proceedings. The available extract does not set out the tribunal's final finding.

11. Upasana Chopra,Chennai vs ITO, Ncw-12(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 8 June 2026
Sections engaged: 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 858/Chny/2026 for Assessment Year 2019-20) was filed by the assessee, an individual, against the CIT(A)/NFAC order dated 19.12.2025. The hearing was held on 16 April 2026 and the order pronounced on 8 June 2026. The source preview is procedural in nature and does not disclose the substantive findings or quantum of any penalty in the available extract.

12. Income Tax Officer, Race Course Road vs Anamallais Bus Transport Private

Bench: Income Tax Appellate Tribunal - Chennai
Date: 8 June 2026
Sections engaged: 269S, 273B
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 2513/Chny/2024 for Assessment Year 2018-19) was filed by the Revenue against an order dated 01.08.2024 passed by the CIT(A)/NFAC. Unlike most other matters in this compilation, the appellant here is the Income Tax Officer (Corporate Ward 1, Coimbatore) and the respondent is the assessee company, Anamallais Bus Transport Private Limited. The hearing took place on 15 April 2026 and the order was pronounced on 8 June 2026; the source preview does not disclose the substantive findings in the available extract.

Patterns across these 12 rulings

Section 273B as a companion provision. In every case in this compilation, Section 273B appears alongside one or more primary penalty sections — most frequently in combination with Section 271B (audit default) or Section 271D (cash loan restrictions). This confirms the consistent practice of pleading Section 273B as a statutory defence in parallel with the challenge to the underlying penalty.
NFAC as the first appellate authority. In the majority of these matters, the order under appeal before the ITAT was passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi. This reflects the nationwide routing of first appeals through the faceless mechanism and the resulting concentration of second-appeal work at ITAT benches.
Procedural threshold issues arising before merits. At least one case in this set (Partyaksh Sharma, case 4) required the tribunal to deal with a condonation of delay application before reaching the merits, with a reported delay of 173 days attributed to belated discovery of the order by a newly engaged tax consultant. This illustrates that procedural compliance at the appellate stage is itself a live issue in penalty matters.
Revenue-initiated appeals present in the set. Case 12 (Income Tax Officer vs. Anamallais Bus Transport Private) is a Revenue appeal, demonstrating that Section 273B-related litigation is not exclusively assessee-driven; the Revenue may also appeal against first-appellate orders that granted the reasonable-cause defence.
Assessment years spanning over a decade. The assessment years across these twelve rulings range from AY 2011-12 (case 2) to AY 2022-23 (case 8), reflecting the extended lifecycle of penalty proceedings in the Indian income-tax system and the significant lag between the assessment year and the ITAT pronouncement date.

How to use this compilation

This compilation is structured as a research starting point, not an end point. Each entry provides the identity fields — bench, date, sections engaged, and ITA number where available in the source preview — to enable a researcher to locate the full judgment on indiankanoon.org, the official ITAT e-filing portal, or a subscribed legal database. Researchers should always verify the full text of the judgment before relying on any holding, because the source previews reproduced here are necessarily partial and may not capture qualifications, conditions, or directions set out later in the order.

Before applying any ruling to a live matter, researchers should also check whether the order has been appealed further to the High Court or the Supreme Court, whether any stay has been granted against the operation of the order, and whether the relevant bench has issued a subsequent order modifying or recalling the earlier decision. Indian tax litigation frequently involves parallel proceedings — reassessment, rectification, or stay applications — that may affect the operative effect of an ITAT order even after it is formally pronounced.

Finally, researchers should cross-reference the CBDT's circulars and instructions on the administration of penalty provisions, as administrative guidance on reasonable cause and penalty waiver may supplement or contextualise the judicial positions emerging from these rulings. The sections cited in each case should be read in their current, amended form, as the Income Tax Act has undergone several amendments that may affect the text applicable to a given assessment year.

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 273B Income Tax Penalty Defences: 12 ITAT Rulings (2026)