Bundelkhand University, Jhansi v. Assessment Unit (Exemption)
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Case in 2 minutes
The reported ruling concerns a technical/venial compliance lapse where information was ultimately supplied before completion. It reports deletion of the penalty on the factual chronology.
Case snapshot
Sections / provisions: 272A(1)(d)
Questions before the Court / Tribunal
- Penalty for notice compliance where details ultimately furnished: The reported ruling concerns a technical/venial compliance lapse where information was ultimately supplied before completion. It reports deletion of the penalty on the factual chronology.
Material facts and background
of the assessee to furnish the requisite details at the time of assessment proceedings. I find that ultimately the assessment was completed only under section 143(3) of the Act after taking into account all the requisite details filed by the assessee. Even the fact of assessee furnishing all the details had been conceded by the Learned AO in page 3 of his order. Hence, for a mere technical venial breach committed by the Assessee, in my considered opinion, the Assessee should not be invited with the levy of penalty under Section 272A(1)(d) of the Act in the facts and circumstances of the instant case. My view is further fortified by the decision of the Coordinate Bench of Delhi Tribunal in the case of Akhil Bhartiya Pratmik Shamshak Sangh Bhavan Trust v ADIT reported in 115 TTJ 419. Similar view was also taken by the Coordinate Bench of Raipur Tribunal in the case of Mrs. Bhavna Modi v ITO in ITA No. 298 /Rpr/ /2024 for assessment year 20-21 and Coordinate Bench of Cochin Tribunal in the case of Jomon John v NFAC in ITA No. 578/ Coch / 2024 for assessment year 2017-18 dated 29-04-2025. 4.
In the result, the appeal of the Assessee is allowed. Order pronounced in the open court on 03/09/2025. Sd/(M. BALAGANESH) ACCOUNTANT MEMBER
Appellant / assessee submissions
The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.
Revenue / respondent submissions
The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.
Court / Tribunal analysis and reasoning
record. The Assessee University has been formed and enacted through the Uttar Pradesh State University Act , 1973 and fully governed by the Bundelkhand University First Statutes, 1977 as enacted by the Governor of Uttar Pradesh under the powers conferred under the provisions of the Uttar Pradesh State University Act, 1973. The Assessee University is existing solely for educational purposes only and not for the purpose of profit. The surplus of receipts over expenditure are accumulated over the years and such surplus had been ploughed back to the coffers of the Assessee University for educational purposes. The Assessee University had received direct grant from the Government of Uttar Pradesh at the time of formation of University whereby land and expenditure incurred to create building, other infrastructure facilities etc was wholly funded by Government of Uttar Pradesh to run educational institution and University is regularly receiving the grant from Government from time to time in every financial year. The Learned AO however observed that the Assessee had received only 2.39 percent of total receipts as grant from the Government and hence would not comply with the provisions of...
of the assessee to furnish the requisite details at the time of assessment proceedings. I find that ultimately the assessment was completed only under section 143(3) of the Act after taking into account all the requisite details filed by the assessee. Even the fact of assessee furnishing all the details had been conceded by the Learned AO in page 3 of his order. Hence, for a mere technical venial breach committed by the Assessee, in my considered opinion, the Assessee should not be invited with the levy of penalty under Section 272A(1)(d) of the Act in the facts and circumstances of the instant case. My view is further fortified by the decision of the Coordinate Bench of Delhi Tribunal in the case of Akhil Bhartiya Pratmik Shamshak Sangh Bhavan Trust v ADIT reported in 115 TTJ 419. Similar view was also taken by the Coordinate Bench of Raipur Tribunal in the case of Mrs. Bhavna Modi v ITO in ITA No. 298 /Rpr/ /2024 for assessment year 20-21 and Coordinate Bench of Cochin Tribunal in the case of Jomon John v NFAC in ITA No. 578/ Coch / 2024 for assessment year 2017-18 dated 29-04-2025. 4.
judicial precedents relied upon herein above, I hold that this is not a fit case for levy of penalty under Section 272A(1)(d) of the Act and accordingly direct the Learned AO to cancel the same. Accordingly, the grounds raised by the Assessee are allowed.
Operative decision and relief
record. The Assessee University has been formed and enacted through the Uttar Pradesh State University Act , 1973 and fully governed by the Bundelkhand University First Statutes, 1977 as enacted by the Governor of Uttar Pradesh under the powers conferred under the provisions of the Uttar Pradesh State University Act, 1973. The Assessee University is existing solely for educational purposes only and not for the purpose of profit. The surplus of receipts over expenditure are accumulated over the years and such surplus had been ploughed back to the coffers of the Assessee University for educational purposes. The Assessee University had received direct grant from the Government of Uttar Pradesh at the time of formation of University whereby land and expenditure incurred to create building, other infrastructure facilities etc was wholly funded by Government of Uttar Pradesh to run educational institution and University is regularly receiving the grant from Government from time to time in every financial year. The Learned AO however observed that the Assessee had received only 2.39 percent of total receipts as grant from the Government and hence would not comply with the provisions of...
Authorities and precedents appearing in the judgment
- No reliable precedent list was extracted automatically; use the full judgment for the citation chain.
This list is machine-assisted from the judgment text and is not a substitute for checking the full citation chain in the PDF.
Ratio and legal principle
The decision turns on Penalty for notice compliance where details ultimately furnished. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Why this judgment matters
The case is relevant to taxpayers, advisers and litigators dealing with Penalty for notice compliance where details ultimately furnished. Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
Practitioner action points
- Check the exact penalty charge in the show-cause notice, the assessment finding and the final penalty order; ambiguity or a changed statutory limb can be material.
- For litigation, attach the full judgment/order to the working paper and cite the paragraph/page supporting the proposition rather than relying on a headnote alone.
Do not over-read this case
- The packaged PDF is not yet an issuing-authority certified copy
- Apply the statutory law applicable to the relevant year; later amendments can change the result.
- Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Finin2min Judgment Intelligence
Decision support built around the judgment: reliance, fact match, Q&A, section impact, related-case network and practical next steps.
Can I rely on this judgment?
| Authority level | ITAT |
|---|---|
| Reliance effect | Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. |
| Source integrity | A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending. |
| Subsequent history | Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. |
| Finin2min status | Later-history check open |
Does this case match your facts?
Stronger match when
- Your dispute raises the same core issue: Penalty for notice compliance where details ultimately furnished.
- The same statutory provisions or materially equivalent provisions apply: 272A(1)(d).
- Your matter is at a comparable penalty stage.
- Your documentary/evidentiary record is materially similar to the facts the ITAT Agra considered: of the assessee to furnish the requisite details at the time of assessment proceedings.
- The same legal regime or assessment-period rules relevant to AY 2018-19 apply to your matter.
Weaker / distinguishable when
- A later Supreme Court or jurisdictional High Court ruling changes the legal position.
- The statutory provision was amended for your year or transaction.
- Your evidence, transaction structure, notice chronology or procedural stage differs on a fact the judgment treated as material.
- The case succeeded on a narrow jurisdictional/procedural defect that the authority has cured in your matter.
Questions this judgment answers
What was the main dispute in Bundelkhand University, Jhansi?
The reported ruling concerns a technical/venial compliance lapse where information was ultimately supplied before completion. It reports deletion of the penalty on the factual chronology.
Which facts mattered most to the result?
of the assessee to furnish the requisite details at the time of assessment proceedings. I find that ultimately the assessment was completed only under section 143(3) of the Act after taking into account all the requisite details filed by the assessee. Even the fact of assessee furnishing all the details had been conceded by the Learned AO in page 3 of his order.
What did the ITAT Agra ultimately decide?
record. The Assessee University has been formed and enacted through the Uttar Pradesh State University Act , 1973 and fully governed by the Bundelkhand University First Statutes, 1977 as enacted by the Governor of Uttar Pradesh under the powers conferred under the provisions of the Uttar Pradesh State University Act, 1973. The Assessee University is existing solely for educational purposes only and not for the purpose of profit.
What legal principle can be taken from this judgment?
The decision turns on Penalty for notice compliance where details ultimately furnished. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Which provisions should be checked before relying on the case?
The case engages 272A(1)(d). The relevant statutory version for AY 2018-19 should be checked together with any later amendment, notification, circular and controlling higher-court authority.
When is this judgment most useful to a taxpayer or adviser?
The case is relevant to taxpayers, advisers and litigators dealing with Penalty for notice compliance where details ultimately furnished . Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
What could make this judgment distinguishable or unsafe to rely on?
The packaged PDF is not yet an issuing-authority certified copy Apply the statutory law applicable to the relevant year; later amendments can change the result. Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Can this judgment be cited as current law without another check?
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.
Section / provision impact
- 272A(1)(d) — 272A(1)(d) is part of the statutory framework considered in the context of penalty for notice compliance where details ultimately furnished. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.
How the decision changes your analysis
Before using this authority, frame the issue under 272A(1)(d) and identify the decisive facts/evidence. The result should not be assumed from the case title alone.
The decision turns on Penalty for notice compliance where details ultimately furnished. The operative result is classified as Operative order controls. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.
Case network: similar and different outcomes
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Related cases with a different result
Related-case links are repository similarity connections, not a claim that one judgment cites or overrules another. Use the cited-authority list and later-history check for formal precedent analysis.
Working-paper citation
Full judgment and source trail
Read / download the clean local judgment copy
| Packaged source class | SANITIZED_LOCAL_FULL_JUDGMENT_COPY_PRIMARY_PENDING |
|---|---|
| Pages | 4 |
| SHA-256 | 5b8d2b4c08ff2c39e0a98381b4fac58f606a188398f058943031dfb0e288288b |
| Original source URL | Not exposed publicly. Original provenance retained only in the private source-closure ledger. |
| Source authentication | Sanitized local full-text copy - official primary replacement pending |