This compilation indexes twelve income-tax tribunal and High Court orders, pronounced between 29 June 2026 and 23 July 2026, in which Section 274 of the Income-tax Act, 1961 — the procedural gateway for levying penalties — featured as a section engaged. The rulings span multiple ITAT benches (Bangalore, Ahmedabad, Chennai, Lucknow, Rajkot, Hyderabad, Delhi) and two Bombay High Court writ petitions. The collection is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, citation-ready index of recent Section 274-linked proceedings across diverse penalty provisions (sections 270A, 271(1)(c), 271D, 271E, and 271A, among others).

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers must consult the full text of each judgment and qualified advisers before relying on any ruling for compliance or litigation purposes.

The statutory framework in one paragraph

Section 274 of the Income-tax Act, 1961 prescribes the procedure that the Assessing Officer must follow before imposing any penalty under Chapter XXI of the Act. It requires that the assessee be given a reasonable opportunity of being heard before a penalty order is made. Where the penalty exceeds a specified threshold, the matter must be referred to the Inspecting Assistant Commissioner (now the Joint Commissioner). The section also governs the form of the show-cause notice, and courts have consistently treated compliance with Section 274 — including adequate specification of the charge in the notice — as a jurisdictional prerequisite to a valid penalty order.

The 12 rulings

1. Santhosh Sagar Reddy,Bengaluru vs Income Tax Officer, Ward-4(2)(3)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 23 July 2026
Sections engaged: 143(3), 270A, 274, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 2798/Bang/2025) was filed by the assessee against the order of the National Faceless Assessment Centre for Assessment Year 2018-19. Per the source preview, the assessee had filed the original return of income on 31.12.2018 admitting total income of Rs. 11,50,000/- by opting for presumptive taxation, and the case was selected for limited scrutiny; the appeal engages sections 270A and 274, indicating that penalty proceedings formed part of the issues placed before the Tribunal.

2. Nishit Dhirajlal Doshi,Ahmedabad vs D.C.I.T. Circle 2(1)(1), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 22 July 2026
Sections engaged: 143(3), 263, 271(1)(c), 274, 57
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1903/Ahd/2026) relates to Assessment Year 2014-15. Per the source preview, the assessee filed a return declaring total income of Rs. 83,07,980/-, the assessment under section 143(3) was completed on 05.12.2016 accepting the returned income, and subsequently the Principal Commissioner of Income Tax invoked section 263 and set aside the assessment; the engagement of sections 271(1)(c) and 274 indicates that penalty proceedings were also in issue before the Tribunal.

3. Sanket Vinayak Nagvekar vs Income Tax Officer Ward 4 And Ors

Bench: Bombay High Court
Date: 20 July 2026
Sections engaged: 142(1), 143(2), 144(1), 144C, 144C(1), 144C(15)(b), 147, 148, 148A(b), 148A(d), 156, 270A
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 6094 of 2023) under Article 226 of the Constitution of India challenged, among other things, the notice issued under section 148A(b) dated 17th March 2022, the order under section 148A(d) dated 31st March 2022, the notice under section 148 dated 31st March 2022 for Assessment Year 2018-19, the assessment order dated 30th March 2023 passed under section 147 read with section 144, the consequential demand notice under section 156, and the notice issued under section 274 read with section 270A. The petitioner's challenge, per the source preview, was that the impugned proceedings were without jurisdiction, in violation of sections 144C and 144, contrary to the Faceless Assessment Framework, and violative of principles of natural justice.

4. Nalli Silk Sarees Pvt Ltd.,Chennai vs DCIT Central Circle 3(4), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 15 July 2026
Sections engaged: 270A(9)(e), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA Nos. 450 to 454/CHNY/2026) were filed by Nalli Trust and Nalli Silk Sarees Pvt. Ltd. covering Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, and 2021-22. Per the source preview, the proceedings before the Tribunal engaged sections 270A(9)(e) and 274, indicating that penalty proceedings relating to under-reporting or misreporting of income formed the central issue across the five consolidated appeals.

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

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 8 July 2026
Sections engaged: 132(4), 246, 246A, 253, 263, 264, 269S, 271D, 274, 275(1), 275(1)(a), 275(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: Four consolidated appeals (ITA Nos. 2814, 2815, 2816 & 2817/Bang/2025) were filed by the same assessee for Assessment Years 2016-17, 2017-18, 2018-19, and 2020-21, heard together as a matter of convenience with the assessment year 2016-17 treated as the lead case. Per the source preview, the appeals arise out of a similar factual matrix and the bench directed that the decision in the lead case shall apply mutatis mutandis to the remaining appeals; the engagement of sections 271D and 274 indicates penalty proceedings, alongside limitation-related provisions under section 275(1), 275(1)(a), and 275(1)(b), were in issue.

6. Competent Stock Brokers Private vs DCIT/ACIT Cent, Bareilly-1, Bareilly

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 6 July 2026
Sections engaged: 115B, 132, 133(6), 139(1), 142(1), 143(3), 147, 148, 271A, 274, 68, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (ITA No. 716/LKW/2025 for Assessment Year 2019-20 and ITA Nos. 718 & 719/LKW/2025 for Assessment Years 2019-20 and 2020-21) involving Competent Stock Brokers Private Limited and Yamunaview Towers Private Limited were taken up together and disposed of through a common order. Per the source preview, the assessee e-filed its return of income for the year under consideration on 21.10.2019 under section 139(1); the engagement of sections 271A and 274 indicates that penalty proceedings for failure to maintain or produce accounts or documents were among the issues addressed.

7. Milind Dashrath Pawar vs National Faceless Assessment Centre

Bench: Bombay High Court
Date: 6 July 2026
Sections engaged: 142(1), 142A, 142A(1), 144, 144B, 147, 148, 153(2), 156, 271(1)(c), 274, 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 4539 of 2023) before the Bombay High Court engaged, among other things, limitation questions arising from a reference to the District Valuation Officer under section 142A, the DVO's report finalisation, and the computation of the extended limitation period under section 153(2) as read with TOLA. Per the source preview, the petition also involved a notice under section 156 and proceedings under sections 271(1)(c) and 274, indicating that penalty proceedings were part of the challenge alongside the primary limitation and jurisdiction questions.

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

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 6 July 2026
Sections engaged: 143(3), 154, 269T, 271E, 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 608/Rjt/2026) relates to Assessment Year 2017-18. Per the source preview, the assessee had declared total business income as NIL for Assessment Year 2017-18, the case was selected for scrutiny and assessment under section 143(3) was completed accepting the returned income, and subsequently an order under section 154 read with section 143(3) was passed determining the total income at ₹22,500; the engagement of sections 271E and 274 indicates that penalty proceedings for repayment of loans or deposits otherwise than by account payee cheque or account payee bank draft were also in issue.

9. Deputy Commissioner Of Income Tax vs Ethirajulu Vajravel Kumaran, Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 3 July 2026
Sections engaged: 132(4), 139(1), 153A, 254(2), 270A, 270A(9), 270A(9)(e), 271(1)(c), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The proceedings (M.A. Nos. 33 to 37/CHNY/2026, arising in ITA Nos. 1650, 1651, 1652, 1653/CHNY/2025) span Assessment Years 2015-16, 2017-18, and 2019-20 (per the source preview) and were brought as miscellaneous applications before the Tribunal. The engagement of sections 270A, 270A(9), 270A(9)(e), 271(1)(c), and 274 indicates that the penalty characterisation — and the applicable penalty provision — formed the central issue before the Tribunal in these miscellaneous applications.

10. Narasimham Palanki,Hyderabad vs ITO, Ward-9(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 1 July 2026
Sections engaged: 246, 246A, 269S, 271D, 271E, 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 354/Hyd/2026) for Assessment Year 2017-18 was filed by the assessee feeling aggrieved by the order of the CIT(A), National Faceless Appeal Centre, Delhi, dated 13.03.2025. Per the source preview, there was a delay of 249 days in filing the present appeal before the Tribunal and the assessee filed a petition for condonation of delay supported by an affidavit; the engagement of sections 271D, 271E, and 274 indicates that penalty proceedings concerning acceptance or repayment of loans or deposits in contravention of section 269S were the substantive issues in the appeal.

11. M/S Disinfecto Chemical Industries vs Asstt. Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 30 June 2026
Sections engaged: 143(3), 148, 250, 271(1)(c), 274, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 896/LKW/2025) for A.Y. 2011-12 was filed against the order of the CIT(A), NFAC, dated 9.10.2025 under section 250, wherein the CIT(A) had dismissed the assessee's appeal against the penalty under section 271(1)(c) levied by the Assessing Officer on 26.06.2025. Per the source preview, the assessee contended that the CIT(A) erred in confirming a penalty of Rs. 31,580/- when the addition of Rs. 1,05,264/- under section 143(3) was made on the basis of an estimate only and not on actuals, and that no errors were found by the authorities in the underlying assessment.

12. Affluence Digital Solutions India vs ITO, Ward-16(1), Delhi, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 29 June 2026
Sections engaged: 271(1)(c), 274
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 7916/Del/2025) for Assessment Year 2022-23 arose against the CIT(A)/NFAC Delhi's order dated 24.09.2025. Per the source preview, the assessee submitted at the outset of the hearing that the Assessing Officer had issued a notice under section 274 read with section 270A alleging that it had "under reported income which is in consequence of misreporting thereof" rather than specifying the precise charge, raising a question about the adequacy of the notice in identifying the limb of the penalty provision under which the charge was brought.

Patterns across these 12 rulings

Section 274 as a procedural checkpoint across multiple penalty provisions. Across all twelve rulings, section 274 appears not as a standalone substantive provision but as the procedural gateway linked to a range of substantive penalty sections — sections 270A, 270A(9)(e), 271(1)(c), 271A, 271D, and 271E — confirming that it functions as a universal notice and hearing requirement irrespective of the underlying charge.
Notice specificity challenged in multiple forums. At least two rulings (cases 3 and 12) reflect challenges to the content or adequacy of the section 274 notice itself — one at the High Court level (Bombay HC, case 3) as part of a broader jurisdictional challenge, and one at the ITAT level (Delhi, case 12) where the assessee raised at the outset the question of whether the notice adequately identified the specific limb of the penalty provision.
Consolidation of linked appeals is a recurring procedural feature. Multiple sets of proceedings in this compilation were consolidated and decided by way of a common or lead-case order: cases 5 (four AYs consolidated at ITAT Bangalore), case 6 (three ITA numbers heard together at ITAT Lucknow), and case 4 (five ITA numbers consolidated at ITAT Chennai). This reflects a standing practice of hearing related penalty appeals together where the factual matrix is identical.
Faceless assessment and appeal machinery recurs across proceedings. Several appeals in this compilation arose from orders of the National Faceless Assessment Centre or the CIT(A)/NFAC (cases 1, 7, 10, 11, 12), indicating that the shift to faceless proceedings continues to generate appeals — including on penalty-related grounds — that reach both ITAT benches and High Courts.
Limitation and delay issues appear alongside penalty grounds. In at least two cases (cases 5 and 10), limitation-related provisions — sections 275(1), 275(1)(a), 275(1)(b) in case 5, and a 249-day delay in filing in case 10 — appear alongside the substantive penalty grounds, illustrating that both the timeliness of penalty orders and the timeliness of appeals against them remain live issues before appellate forums.

How to use this compilation

This compilation is a structured index, not a digest of decided outcomes. All twelve orders in this index are recorded with outcome direction "Outcome not specified in source," meaning the TaxNoticeAI corpus captures the procedural and preliminary facts from the available text preview but does not confirm the final direction of relief. Researchers should obtain the full text of each judgment from indiankanoon.org, the official ITAT e-Filing portal, or the relevant High Court's cause-list system before citing any ruling in submissions or opinions.

When using cases from this index for research, verify independently whether the order has been stayed, appealed further to the High Court or Supreme Court, or recalled. Tribunal orders under section 254 are subject to rectification applications under section 254(2), and High Court orders in writ jurisdiction may have been appealed by way of letters patent appeal or special leave petition. CBDT circulars and instructions issued after the date of a ruling may also affect the practical significance of the holding, particularly on procedural questions relating to section 274 notices.

Researchers cross-referencing penalty rulings should take care to distinguish between penalty provisions: sections 270A, 271(1)(c), 271A, 271D, and 271E each carry distinct statutory triggers, limitation periods under section 275, and appellate pathways. A ruling on the adequacy of a section 274 notice in the context of one penalty section may not be directly transportable to proceedings under a different penalty section without examining the specific language of the charge and the applicable judicial precedent on that provision.

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 270A & 274 Penalty Proceedings: 12 ITAT and HC Rulings (2026)