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		<title>Gmail Search’s AI Overviews now available globally</title>
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		<dc:creator><![CDATA[Ashwani Kumar]]></dc:creator>
		<pubDate>Mon, 21 Sep 2026 11:39:39 +0000</pubDate>
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					<description><![CDATA[<p>Gmail Search’s AI Overviews now available globally Gmail Search’s AI Overviews now available globally We recently announced the launch of AI Overviews in Gmail search which allows users to ask natural language questions in Gmail’s search bar and get concise summaries and answers without digging through emails. Starting today, we are expanding access to AI… <span class="read-more"><a href="https://www.taxheal.com/gmail-searchs-ai-overviews-now-available-globally.html">Read More &#187;</a></span></p>
]]></description>
										<content:encoded><![CDATA[<h2 class="blog-post-full__title" style="text-align: center;">Gmail Search’s AI Overviews now available globally</h2>
<p><img fetchpriority="high" decoding="async" class="alignnone" src="https://www.ghacks.net/wp-content/uploads/2026/04/gHacks-articles-2026-04-27T095907.949.png" alt="Gmail Search’s AI Overviews now available globally" width="1200" height="900" /></p>
<p>Gmail Search’s AI Overviews now available globally</p>
<p>We recently announced the launch of <a href="https://workspaceupdates.googleblog.com/2026/04/search-faster-and-smarter-with-ai-overviews-in-Gmail-search.html" target="_blank" rel="noopener">AI Overviews in Gmail search</a> which allows users to ask natural language questions in Gmail’s search bar and get concise summaries and answers without digging through emails. Starting today, we are expanding access to AI Overviews in Gmail search to global users (with paid plans) who have their Gmail language set as English. Previously, this was only available to users in the US with their language set as English.</p>
<h3>Getting started</h3>
<p>&nbsp;</p>
<ul>
<li>Admins: This feature will be ON by default if <a href="https://knowledge.workspace.google.com/admin/gemini/manage-access-to-gemini-features-in-workspace-services" target="_blank" rel="noopener">Gemini for Workspace in Gmail is enabled</a> and <a href="https://knowledge.workspace.google.com/admin/gemini/control-workspace-intelligence" target="_blank" rel="noopener">Workspace Intelligence access to Gmail is enabled</a>.</li>
<li><b>End users:</b> This feature is available by default when smart features are enabled. Users must have both “Smart features in Gmail, Chat, and Meet” and “Google Workspace smart features” turned on to access AI Overviews in Gmail search.</li>
</ul>
<p>&nbsp;</p>
<h4>Rollout pace</h4>
<p>&nbsp;</p>
<ul>
<li><a href="https://support.google.com/a/answer/172177" target="_blank" rel="noopener">Rapid Release domains:</a> Gradual rollout (up to 15 days for feature visibility) started on September 3, 2026</li>
<li><a href="https://support.google.com/a/answer/172177" target="_blank" rel="noopener">Scheduled Release domains:</a> Full rollout (1–3 days for feature visibility) starting on September 21, 2026</li>
<li><b>Personal Google Accounts (Consumer):</b> Gradual rollout started on September 3, 2026</li>
</ul>
<p>&nbsp;</p>
<h4>Availability</h4>
<p>&nbsp;</p>
<ul>
<li><b>Business:</b> Business Starter, Standard, and Plus</li>
<li><b>Enterprise: </b>Enterprise Starter, Standard, and Plus</li>
<li><b>Consumers:</b> Google AI Plus, Pro, and Ultra (excluding personal accounts in the EEA, UK, Switzerland, and Japan)</li>
<li><b>Other Editions: </b>Frontline Plus</li>
<li><b>Education Add-ons:</b> Google AI Pro for Education</li>
<li><b>Other Add-ons:</b> AI Expanded Access</li>
</ul>
<p>&nbsp;</p>
<h4>Resources</h4>
<p>&nbsp;</p>
<ul>
<li>Google Workspace Admin Help: <a href="https://knowledge.workspace.google.com/admin/gemini/manage-access-to-gemini-features-in-workspace-services" target="_blank" rel="noopener">Manage access to Gemini features in Workspace services</a></li>
<li>Google Help: <a href="https://support.google.com/mail/answer/16789526" target="_blank" rel="noopener">Get an AI Overview in Gmail search</a></li>
<li>Google Workspace Updates Blog: <a href="https://workspaceupdates.googleblog.com/2026/04/search-faster-and-smarter-with-ai-overviews-in-Gmail-search.html" target="_blank" rel="noopener">Search faster and smarter with AI Overviews in Gmail search</a></li>
<li>Consumer Launch Blog: <a href="https://blog.google/products-and-platforms/products/gmail/gmail-is-entering-the-gemini-era/" target="_blank" rel="noopener">Gmail is entering the Gemini era</a></li>
</ul>
<p><img decoding="async" src="https://storage.googleapis.com/gweb-uniblog-publish-prod/images/Search_SocialShare_7gpZ6Zv.width-1300.jpg" alt="Google I/O 2024: New generative AI experiences in Search" /></p>
<div data-sfc-cp="" data-sfc-root="ep"><mark data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Gmail Search’s AI Overviews have officially expanded globally<!--TgQPHd|||[]--></span>, allowing users worldwide to ask natural language questions directly within the Gmail search bar<!--TgQPHd|||[]--></mark>. Powered by Google&#8217;s <span data-sfc-cp="" data-sfc-root="ep">Gemini AI<!--TgQPHd|||[]--></span>, this feature synthesizes information scattered across multiple emails to provide concise summaries and direct answers at the top of your inbox, eliminating the need to manually dig through individual threads.<span data-sfc-root="ep"> [1, 2, 3, 4] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></div>
<div data-sfc-cp="" data-sfc-root="ep">
<div></div>
<p><!--TgQPHd|||[]--></p>
<ul>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Target Audience:<!--TgQPHd|||[]--></span> The global rollout is currently live for <span data-sfc-cp="" data-sfc-root="ep">paid Google Workspace and Google AI subscribers<!--TgQPHd|||[]--></span>. This includes plans like Google Workspace Business (Starter, Standard, Plus), Enterprise editions, Frontline Plus, and Education accounts with AI add-ons.<span data-sfc-root="ep"> [1, 5, 6] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></li>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Language Requirements:<!--TgQPHd|||[]--></span> At launch, the feature is <span data-sfc-cp="" data-sfc-root="ep">exclusive to users who have their preferred Gmail language set to English<!--TgQPHd|||[]--></span>. Google plans to introduce additional language support in future updates.<span data-sfc-root="ep"> [1, 4, 6] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></li>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Supported Platforms:<!--TgQPHd|||[]--></span> The feature is gradually rolling out across <span data-sfc-cp="" data-sfc-root="ep">Android, iOS, and the web<!--TgQPHd|||[]--></span>.<span data-sfc-root="ep"> [3, 7, 8] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--><!--TgQPHd|||[]--></li>
</ul>
<p><!--TgQPHd|||[]--></div>
<div data-sfc-cp="" data-sfc-root="ep">Instead of matching strict keywords, the search bar now understands context. You can type questions like <em data-sfc-root="ep">&#8220;When is my flight to Hawaii?&#8221;<!--TgQPHd|||[]--></em> or <em data-sfc-root="ep">&#8220;What was the final budget agreed upon with the supplier?&#8221;<!--TgQPHd|||[]--></em>.<span data-sfc-root="ep"> [3, 5] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></div>
<div data-sfc-root="ep"><!--TgQPHd|||[]--></div>
<div data-sfc-cp="" data-sfc-root="ep">
<div></div>
<p><!--TgQPHd|||[]--></p>
<ul>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Instant Summaries:<!--TgQPHd|||[]--></span> A dedicated AI Overview panel appears right above your standard search results.<span data-sfc-root="ep"> [3, 9] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></li>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Interactive Citations:<!--TgQPHd|||[]--></span> The generated summary includes clickable references to the source emails, allowing you to quickly verify the origin of the information.<span data-sfc-root="ep"> [9] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--></li>
<li data-sfc-cp="" data-sfc-root="ep"><span data-sfc-cp="" data-sfc-root="ep">Privacy Controls:<!--TgQPHd|||[]--></span> Google maintains that queries are encrypted and are not used to train Gemini AI models. If you prefer not to use it, you can turn off the capability entirely by disabling &#8220;Smart features in Google Workspace&#8221; inside your <a href="https://support.google.com/mail/answer/10079371" data-sfc-cp="" data-sfc-root="ep">Gmail Settings<!--TgQPHd|||[]--></a>.<span data-sfc-root="ep"> [6, 7, 10] <!--TgQPHd|||[]--></span><!--TgQPHd|||[]--><!--TgQPHd|||[]--></li>
</ul>
<p><!--TgQPHd|||[]--></div>
<div data-sfc-cp="" data-sfc-root="ep">If you want to try this out, let me know:<!--TgQPHd|||[]--></div>
<div data-sfc-cp="" data-sfc-root="ep">
<div></div>
<p><!--TgQPHd|||[]--></p>
<ul>
<li data-sfc-cp="" data-sfc-root="ep">Do you have a <span data-sfc-cp="" data-sfc-root="ep">paid Google Workspace<!--TgQPHd|||[]--></span> or <span data-sfc-cp="" data-sfc-root="ep">Google One AI Premium<!--TgQPHd|||[]--></span> subscription?<!--TgQPHd|||[]--></li>
<li data-sfc-cp="" data-sfc-root="ep">What <span data-sfc-cp="" data-sfc-root="ep">type of device<!--TgQPHd|||[]--></span> (Desktop, Android, iOS) are you using to access Gmail?<!--TgQPHd|||[]--><!--TgQPHd|||[]--></li>
</ul>
<p><!--TgQPHd|||[]--></div>
<div data-sfc-root="ep"><!--TgQPHd|||[]--></div>
<h4></h4>
<h4>Read more</h4>
<p>. <a href="https://www.taxheal.com/introducing-jiotag-2.html" target="_blank" rel="noopener">Introducing JioTag 2</a></p>
<p>. <a href="https://www.taxheal.com/inside-the-gemma…-gemma-downloads.html" target="_blank" rel="noopener">Inside the Gemmaverse: Celebrating one billion Gemma downloads</a></p>
<p>. <a href="https://www.taxheal.com/personalize-the-content-you-see-on-search-discover-and-news.html" target="_blank" rel="noopener">Personalize the content you see on Search, Discover, and News</a></p>
<p>. <a href="https://www.taxheal.com/gemini-in-google-sheets-is-now-available-on-android-devices.html" target="_blank" rel="noopener">Gemini in Google Sheets is now available on Android devices</a></p>
<p>&nbsp;</p>
<p>. <a href="https://www.taxheal.com/the-gemini-desktop-app-is-now-available-for-windows.html" target="_blank" rel="noopener">The Gemini desktop app is now available for Windows</a></p>
<p>. <a href="https://www.taxheal.com/macos-27-golden-gate-is-incredible-first-15-things.html" target="_blank" rel="noopener">macOS 27 Golden Gate is INCREDIBLE! &#8211; First 15 Things</a></p>
<p>. <a href="https://www.taxheal.com/take-an-interactive-journey-through-americas-national-parks.html" target="_blank" rel="noopener">Take an interactive journey through America’s national parks</a></p>
<p>. <a href="https://www.taxheal.com/seamlessly-import-your-team-and-data-from-microsoft-to-google-workspace-during-setup.html" target="_blank" rel="noopener">Seamlessly import your team and data from Microsoft to Google Workspace during setup</a></p>
<p>. <a href="https://www.taxheal.com/google-workspace-weekly-recap-september-11-2026.html" target="_blank" rel="noopener">Google Workspace Weekly Recap &#8211; September 11, 2026</a></p>
<p>. <a href="https://www.taxheal.com/set-up-sharing-boundaries-for-google-drive-with-unified-data-protection-rules.html" target="_blank" rel="noopener">Set up sharing boundaries for Google Drive with unified data protection rules</a></p>
<p>. <a href="https://www.taxheal.com/gpt-live-1-is-now-in-the-api.html" target="_blank" rel="noopener">GPT-Live-1 is now in the API</a></p>
<p>. <a href="https://www.taxheal.com/new-and-improved-github-copilot-harness-agent-skills-and-richer-context.html" target="_blank" rel="noopener">New and improved: GitHub Copilot harness, agent skills, and richer context</a></p>
<p>. <a href="https://www.taxheal.com/tap-to-pay-with-google-pay-is-coming-to-walmart.html" target="_blank" rel="noopener">Tap to pay with Google Pay is coming to Walmart</a></p>
<p><strong>for more refer Gemini website <a href="https://gemini.google.com/" target="_blank" rel="noopener">click here</a></strong></p>
<p><strong>for more refer Artificial Intelligence  website <a href="https://indiaai.gov.in/" target="_blank" rel="noopener">click here</a></strong></p>
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		<title>Aadhaar Authentication for National Career Service Project Amendment Rules 2025 Notification</title>
		<link>https://www.taxheal.com/aadhaar-authentication-for-national-career-service-project-amendment-rules-2025-notification.html</link>
		
		<dc:creator><![CDATA[Ashwani Kumar]]></dc:creator>
		<pubDate>Wed, 26 Aug 2026 07:56:21 +0000</pubDate>
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					<description><![CDATA[<p>Aadhaar Authentication for National Career Service Project Amendment Rules 2025 Notification Publication of Notification of the Aadhaar Authentication for Good Governance Social Welfare Innovation Knowledge Rules 2020 as amended in 2025 for National Career Service NCS Project in the Gazette of India Part II Section 3 Sub Section ii The Gazette of India CG-DL-E-25082026-275761 EXTRAORDINARY… <span class="read-more"><a href="https://www.taxheal.com/aadhaar-authentication-for-national-career-service-project-amendment-rules-2025-notification.html">Read More &#187;</a></span></p>
]]></description>
										<content:encoded><![CDATA[<h2 style="text-align: center;">Aadhaar Authentication for National Career Service Project Amendment Rules 2025 Notification</h2>
<h4 style="text-align: center;">Publication of Notification of the Aadhaar Authentication for Good Governance Social Welfare Innovation Knowledge Rules 2020 as amended in 2025 for National Career Service NCS Project in the Gazette of India Part II Section 3 Sub Section ii</h4>
<p><img decoding="async" class="aligncenter" src="https://upload.wikimedia.org/wikipedia/commons/7/75/Logo_of_the_Gazette_of_India.svg?utm_source=en.wikipedia.org&amp;utm_campaign=index&amp;utm_content=original" alt="Aadhaar Authentication for National Career Service Project Amendment Rules 2025 Notification" width="678" height="261" /></p>
<h2 style="text-align: center;"><strong>The Gazette of India</strong></h2>
<p style="text-align: center;"><strong>CG-DL-E-25082026-275761</strong></p>
<p style="text-align: center;"><strong>EXTRAORDINARY</strong></p>
<p style="text-align: center;"><strong>PART II—Section 3—Sub-section (ii)</strong></p>
<p style="text-align: center;"><strong>PUBLISHED BY AUTHORITY</strong></p>
<p style="text-align: center;"><strong>No. 4483] NEW DELHI, MONDAY, AUGUST 24, 2026/BHADRA 2, 1948</strong></p>
<p>MINISTRY OF LABOUR AND EMPLOYMENT<br />
NOTIFICATION<br />
New Delhi, the 24th August, 2026</p>
<p>S.O. 4666(E).— Whereas the use of Aadhaar number to establish identity enables individuals to receive<br />
subsidies, benefits and services in a convenient and seamless manner, obviates the need for multiplicity of documents<br />
to establish identity, simplifies processes and promotes transparency and efficiency;<br />
And whereas the Ministry of Electronics and Information Technology, Government of India, after consultation<br />
with the Unique Identification Authority of India (UIDAI), had allowed vide its letter no. eF. No. 13(16)/2022-EG-II,</p>
<p>dated 6th May, 2026 to the Ministry of Labour and Employment (hereinafter referred to as the said Ministry),</p>
<p>Government of India (hereinafter referred to as the said Government) for the purposes specified under sub-rule (1) of<br />
rule 3 of the Aadhaar Authentication for Good Governance (Social Welfare, Innovation, Knowledge) Rules, 2020<br />
(hereinafter referred to as the said rules) and for the said purpose, the Directorate General of Employment, an attached<br />
of the said Ministry (hereinafter referred to as the said organisation) may be allowed to perform authentication and be<br />
permitted the use of Aadhaar number during authentication for establishing identity of Aadhaar number holder and<br />
notify the same under rule 5 of the said rules read with sub-clause (ii) of clause (b) of sub-section (4) of section 4 of the<br />
Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 (hereinafter referred to<br />
as the Act);</p>
<p>And whereas, the Aadhaar authentication shall be performed for employment related assistance (hereinafter<br />
referred to as the said purpose) as specified under sub-rule (1) of rule 3 of the said rules on voluntary basis only for<br />
establishing the identity of the employers, counsellors, mentors, training providers, jobseekers, and authorised<br />
signatories of recruitment agencies or career centers, for accessing its portal or mobile application for employment<br />
related assistance including job matching, career counselling, vocational guidance, information on skilling,<br />
apprenticeship opportunities, organising of job fairs and career events to prevent de-duplication, impersonation and<br />
fraudulent activities, and enabling efficient and timely verification, using Yes/No or/and eKYC authentication facilities<br />
[hereinafter referred to as the use case(s)].<br />
Now, therefore, in pursuance of rule 5 of the said rules read with sub-clause (ii) of clause (b) of sub-section (4)<br />
of section 4 of the Act, the said Ministry hereby notifies the following, namely: —</p>
<p>1. (1) The organisation shall obtain the consent of the Aadhaar number holder for the purpose of authentication<br />
herein.<br />
(2) As per sub-rule (2) of rule 3 of the said rules, Aadhaar authentication is on voluntary basis and the<br />
organisation shall inform to the Aadhaar number holder of alternate and viable means of identification and<br />
shall not deny any service to the Aadhaar number holder for refusing to, or being unable to, undergo Aadhaar<br />
authentication, namely:<br />
a. Permanent Account Number (PAN)<br />
b. Passport<br />
c. Voter Identity Card<br />
d. Driving License issued by the Licensing Authority under the Motor Vehicles Act, 1988<br />
e. Others: Employment Exchange ID, UAN(EPFO),UAN(e-Shram)</p>
<p>2. This notification shall come into force on the date of its publication in the Official Gazette.</p>
<p>[F. No. DGE-U-11011/16/2025-NCS(Coord)/AadhaarForNCS]<br />
ANJALI RAWAT, Dy. Director General(E)</p>
<h3>Download PDF <a href="https://www.taxheal.com/wp-content/uploads/2026/08/275761.pdf" target="_blank" rel="noopener">Click here</a></h3>
<h4>Read more</h4>
<p><strong>for more refer Gazette website <a href="https://egazette.gov.in/" target="_blank" rel="noopener">click here</a></strong></p>
<p><strong>for more refer YouTube Subscribe website <a href="https://www.youtube.com/@casatbirsingh" target="_blank" rel="noopener">click here</a></strong></p>
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		<title>Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968 from Download</title>
		<link>https://www.taxheal.com/canara-bank-form-of-nomination-under-the-public-provident-fund-scheme-1968-from-download.html</link>
		
		<dc:creator><![CDATA[Ashwani Kumar]]></dc:creator>
		<pubDate>Wed, 17 Jun 2026 06:44:35 +0000</pubDate>
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					<description><![CDATA[<p>Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968 Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968 from Download Based on the provided document, here are the key points of Canara Bank PPF Form E (NF 356), which is used for registering a nomination under the Public Provident… <span class="read-more"><a href="https://www.taxheal.com/canara-bank-form-of-nomination-under-the-public-provident-fund-scheme-1968-from-download.html">Read More &#187;</a></span></p>
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										<content:encoded><![CDATA[<h2 style="text-align: center;">Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968</h2>
<p>Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968 from Download</p>
<div>Based on the provided document, here are the key points of <mark><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Canara Bank PPF Form E (NF 356)<!--TgQPHd||[]--></span></mark>, which is used for registering a nomination under the Public Provident Fund (PPF) Scheme (NF_356_ASS&#8230; pp. 1-2):</div>
<h4 role="heading" data-sfc-root="ep">Core Form Purpose<!--TgQPHd||[]--></h4>
<div>
<div></div>
<ul>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Nomination Registration<!--TgQPHd||[]--></span>: Allows a PPF subscriber to formally designate one or more individuals to receive their account balance in the event of their death (NF_356_ASS&#8230; p. 1).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Bilingual Format<!--TgQPHd||[]--></span>: Features standard informational fields structured side-by-side in Assamese and English (NF_356_ASS&#8230; p. 1).</li>
</ul>
</div>
<h4 role="heading" data-sfc-root="ep">Nominee Registration Details<!--TgQPHd||[]--></h4>
<div>
<div></div>
<ul>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Account Linkage<!--TgQPHd||[]--></span>: Captures the subscriber&#8217;s name and exact PPF Account Number (NF_356_ASS&#8230; p. 1).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Detailed Mapping Table<!--TgQPHd||[]--></span>: Collects the full name, complete residential address, date of birth (mandatory if the nominee is a minor), and the specific proportionate share percentage allocated to each beneficiary (NF_356_ASS&#8230; p. 1).</li>
</ul>
</div>
<h4 role="heading" data-sfc-root="ep">Minor Guard Rules<!--TgQPHd||[]--></h4>
<div>
<div></div>
<ul>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Guardian Appointment<!--TgQPHd||[]--></span>: If any named nominee is a minor, the subscriber must explicitly designate a legal guardian (including their full name and address) (NF_356_ASS&#8230; p. 1).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Payout Authority<!--TgQPHd||[]--></span>: This appointed guardian is authorized to collect the account funds if the subscriber passes away while the nominee is still a minor (NF_356_ASS&#8230; p. 1).</li>
</ul>
</div>
<h4 role="heading" data-sfc-root="ep">Dispute Resolution &amp; Legal Priority<!--TgQPHd||[]--></h4>
<div>
<div></div>
<ul>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Nominee Preference<!--TgQPHd||[]--></span>: The subscriber explicitly agrees that if a simultaneous claim occurs between the nominee and legal heirs, the bank is legally discharged by settling the claim solely in favour of the nominee (NF_356_ASS&#8230; p. 2).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Court Order Precedence<!--TgQPHd||[]--></span>: The bank reserves the right to override standard nomination terms and act strictly in accordance with any specific court orders issued regarding the PPF account (NF_356_ASS&#8230; p. 2).</li>
</ul>
</div>
<h4 role="heading" data-sfc-root="ep">Verification &amp; Processing<!--TgQPHd||[]--></h4>
<div>
<div></div>
<ul>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Subscriber Validation<!--TgQPHd||[]--></span>: Requires the physical signature or thumb impression of the primary subscriber (NF_356_ASS&#8230; p. 2).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Witness Verification<!--TgQPHd||[]--></span>: Demands the signature, name, address, and date from an independent witness to authenticate the subscriber&#8217;s execution (NF_356_ASS&#8230; pp. 1-2).</li>
<li><span data-sfc-cp="" data-sfc-root="ep" data-sfc-cb="">Official Account Ledger<!--TgQPHd||[]--></span>: Final registration requires the bank&#8217;s Accounts Officer to sign and date the document, certifying that the nomination has been recorded in the bank&#8217;s system and entered into the subscriber&#8217;s physical passbook (NF_356_ASS&#8230; p. 2).</li>
</ul>
</div>
<div>
<h3>Download PDF <a href="https://www.taxheal.com/wp-content/uploads/2026/06/NF_356_ASSAMESE.pdf" target="_blank" rel="noopener">Click here</a></h3>
<p><a href="https://www.taxheal.com/wp-content/uploads/2026/06/Canara-bank.png"><img decoding="async" class="alignnone wp-image-133685 size-full" src="https://www.taxheal.com/wp-content/uploads/2026/06/Canara-bank.png" alt="Canara Bank FORM OF NOMINATION UNDER THE PUBLIC PROVIDENT FUND SCHEME, 1968 from Download" width="600" height="337" srcset="https://www.taxheal.com/wp-content/uploads/2026/06/Canara-bank.png 600w, https://www.taxheal.com/wp-content/uploads/2026/06/Canara-bank-300x169.png 300w" sizes="(max-width: 600px) 100vw, 600px" /></a></p>
<h4>Read more</h4>
<p><a href="https://www.taxheal.com/canara-bank-common-application-cum-appraisal-report-for-credit-facilities-for-agricultural-loan-from-download.html" target="_blank" rel="noopener">Canara Bank Common application cum appraisal report for credit facilities for agricultural loan from Download</a></p>
<p><a href="https://www.taxheal.com/canara-bank-pm-street-vendors-atmanirbhar-nidhipm-svanidhi-loan-application-form-download.html" target="_blank" rel="noopener">Canara Bank PM Street Vendor&#8217;s AtmaNirbhar Nidhi(PM SVANidhi) Loan Application Form Download</a></p>
<p><a href="https://www.taxheal.com/canara-bank-ppf-account-opening-form-download.html" target="_blank" rel="noopener">Canara Bank PPF Account Opening Form Download</a></p>
<p><a href="https://www.taxheal.com/canara-bank-ssa-opening-form-download.html" target="_blank" rel="noopener">Canara Bank SSA Opening Form Download</a></p>
<p><a href="https://www.taxheal.com/canara-bank-scss-a-c-opening-form-download.html" target="_blank" rel="noopener">Canara Bank SCSS A/C Opening Form Download</a></p>
<p>&nbsp;</p>
<p><strong>for more refer Canara Bank  website <a href="https://www.canarabank.bank.in/" target="_blank" rel="noopener">Click here</a></strong></p>
<p><strong>for more refer YouTube Subscribe website <a href="https://www.youtube.com/@casatbirsingh" target="_blank" rel="noopener">click here</a></strong></p>
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		<title>Bank following binding interim High Court orders cannot be treated as an assessee in default.</title>
		<link>https://www.taxheal.com/siddhartha-nautiyal-judicial-member.html</link>
		
		<dc:creator><![CDATA[Ashwani Kumar]]></dc:creator>
		<pubDate>Tue, 02 Jun 2026 05:08:41 +0000</pubDate>
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		<guid isPermaLink="false">https://www.taxheal.com/?p=132463</guid>

					<description><![CDATA[<p>Bank following binding interim High Court orders cannot be treated as an assessee in default. Issue Whether an employer-bank can be treated as an &#8220;assessee in default&#8221; under section 201(1) and charged interest under section 201(1A) for failing to deduct tax at source on foreign-leg Leave Fare Concession (LFC/LTC) reimbursements, if the bank was operating… <span class="read-more"><a href="https://www.taxheal.com/siddhartha-nautiyal-judicial-member.html">Read More &#187;</a></span></p>
]]></description>
										<content:encoded><![CDATA[<div id="model-response-message-contentr_5d463696a38c97e9" class="markdown markdown-main-panel enable-updated-hr-color" dir="ltr" aria-live="polite" aria-busy="false">
<p data-path-to-node="0"><strong>Bank following binding interim High Court orders cannot be treated as an assessee in default.</strong></p>
<h3 data-path-to-node="1">Issue</h3>
<p data-path-to-node="2">Whether an employer-bank can be treated as an &#8220;assessee in default&#8221; under section 201(1) and charged interest under section 201(1A) for failing to deduct tax at source on foreign-leg Leave Fare Concession (LFC/LTC) reimbursements, if the bank was operating under specific interim directions from a High Court stating that such payments would not constitute income for TDS purposes.</p>
<h3 data-path-to-node="3">Facts</h3>
<ul data-path-to-node="4">
<li>
<p data-path-to-node="4,0,0">The assessee-bank granted Leave Fare Concession / Leave Travel Concession (LFC/LTC) to certain employees for journeys that included a foreign destination leg.</p>
</li>
<li>
<p data-path-to-node="4,1,0">The bank did not deduct tax at source (TDS) under section 192 on these travel reimbursements.</p>
</li>
<li>
<p data-path-to-node="4,2,0">It contended that the tax exemption under section 10(5) read with Rule 2B applied to the eligible Indian leg of the travel fare.</p>
</li>
<li>
<p data-path-to-node="4,3,0">Crucially, the bank was operating under binding interim directions issued by the Madras High Court, which explicitly clarified that these LFC reimbursements would not constitute income for TDS purposes.</p>
</li>
<li>
<p data-path-to-node="4,4,0">The High Court&#8217;s interim order also specified that if the underlying writ petition ultimately failed, the consequential tax liability would fall directly on the individual employees, not the bank.</p>
</li>
<li>
<p data-path-to-node="4,5,0">The Assessing Officer (AO) rejected this approach, holding that any travel reimbursement involving a foreign leg became fully taxable as salary.</p>
</li>
<li>
<p data-path-to-node="4,6,0">The AO determined that the bank was legally obligated to deduct TDS under section 192 and subsequently treated the bank as an &#8220;assessee in default&#8221; under section 201(1), while also levying interest under section 201(1A).</p>
</li>
</ul>
<h3 data-path-to-node="5">Decision</h3>
<ul data-path-to-node="6">
<li>
<p data-path-to-node="6,0,0">Held, yes; since the assessee-bank was strictly operating under the binding interim directions of the Madras High Court which protected them from deducting TDS on these payments, it could not be legally treated as an assessee in default under section 201(1) for the period in question.</p>
</li>
<li>
<p data-path-to-node="6,1,0">Held, yes; because the primary declaration of being an &#8220;assessee in default&#8221; was struck down, the consequential interest levied by the AO under section 201(1A) also could not survive and was entirely deleted.</p>
</li>
<li>
<p data-path-to-node="6,2,0">The appeal was decided fully in favor of the assessee-bank.</p>
</li>
</ul>
<h3 data-path-to-node="7">Key Takeaways</h3>
<ul data-path-to-node="8">
<li>
<p data-path-to-node="8,0,0"><b data-path-to-node="8,0,0" data-index-in-node="0">Sanctity of Judicial Orders:</b> An assessee cannot be penalized or held in default by the revenue department for actions that strictly conform to active, binding interim directions issued by a Constitutional Court.</p>
</li>
<li>
<p data-path-to-node="8,1,0"><b data-path-to-node="8,1,0" data-index-in-node="0">TDS Liability Shift:</b> When a High Court&#8217;s interim order explicitly shifts the potential financial risk to the ultimate beneficiaries (the employees) in the event that a petition fails, the revenue cannot retrospectively demand that the withholding agent (the employer) bear the burden.</p>
</li>
<li>
<p data-path-to-node="8,2,0"><b data-path-to-node="8,2,0" data-index-in-node="0">Interest is Consequential:</b> Interest under section 201(1A) is directly tied to the primary status of being an assessee in default under section 201(1). If the underlying default status is invalidated, the interest liability automatically evaporates.</p>
</li>
</ul>
<div id="111070000000000011" style="text-align: center;">IN THE ITAT <span class="researchdochighlight">AHMEDABAD</span> BENCH &#8216;C&#8217;</div>
<div id="" style="text-align: center;">State Bank of India Currency Administration Cell</div>
<div style="text-align: center;">v.</div>
<div id="" style="text-align: center;">Income-tax Officer<sup><a id="anchor_80261.81569937087" class="fnoteuser"></a>*</sup></div>
<div id="dbs_judge" style="text-align: center;"><span id="111170000000109709">Siddhartha Nautiyal</span>, Judicial Member<br />
and <span id="111170000000098996">Narendra Prasad Sinha</span>, Accountant Member</div>
<div style="text-align: center;">I.T. Appeal No.1011 and 1044 (Ahd) OF <span class="researchdochighlight">2026</span><br />
[Assessment years 2016-17 and 2017-18]</div>
<div style="text-align: center;">MAY  8, <span class="researchdochighlight">2026</span></div>
<div>
<div id="digest">
<div><b>Lokesh Karia</b>, AR<i> for the Appellant. </i><b>Amit Pratap Singh</b>, Sr. DR<i> for the Respondent.</i></div>
</div>
<div id="caseOrder">
<div>
<div>ORDER</div>
<div></div>
<div><b>Siddhartha Nautiyal, Judicial Member. </b>&#8211; Both appeals have been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short &#8220;Ld. CIT(A)&#8221;), ADDL/JCIT(A)-2, Siliguri vide orders dated 22.01.2026 &amp; 12.01.2026 passed for A.Y. 2016-17 &amp; 2017-18. Since common facts and issues for consideration are involved for both the appeals before us, both the appeals are being disposed by way of a common order.</div>
<div><b>2. </b>The assessee has taken the following grounds of appeal:</div>
<div><i>ITA No. 1011/Ahd/<span class="researchdochighlight">2026</span> (A. Y. 2016-17)</i></div>
<div>&#8220;In our cases assessing officer has disallowed exemption u/s.10(5) of Income Tax Act, on the base of differences in interpretation of law and treated us as assessee in default and passed order against us u/s. 201(1) and 201(1A) of the Income Tax Act and we filed appeal against said order before CIT (Appeals), which is dismissed and order was issued u/s.250 of the Income Tax Act.</div>
<div>The Kerala High Court has held in a recent judgment that State Bank of India (SBI) cannot be treated as an &#8220;Assessee in Default&#8221; under section 201 of the Income Tax act for not deducting Tax at Source (TDS) on Leave Travel Concession (LTC) payments, as it was bound by an interim order which prohibited such deduction. The copy of said order is attached herewith.</div>
<div>Therefore against said order u/s. 250 and u/s. 201(1) and 201(1A), we prefer to file appeal before ITAT and furnished facts of the case along with said appeal along with relevant documentary evidences and we demand the withdrawal of the same from your honour by allowing our appeal on the basis of grounds and evidences furnished by us. &#8220;</div>
<div><i>ITA No. 1044/Ahd/<span class="researchdochighlight">2026</span> (A. Y. 2017-18)</i></div>
<div>&#8220;In our cases assessing officer has disallowed exemption u/s.10(5) of Income Tax Act, on the base of differences in interpretation of law and treated us as assessee in default and passed order against us u/s. 201(1) and 201(1A) of the Income Tax Act and we filed appeal against said order before CIT (Appeals), which is dismissed and order was issued u/s.250 of the Income Tax Act.</div>
<div>The Kerala High Court has held in a recent judgment that State Bank of India (SBI) cannot be treated as an &#8220;Assessee in Default&#8221; under section 201 of the Income Tax act for not deducting Tax at Source (TDS) on Leave Travel Concession (LTC) payments, as it was bound by an interim order which prohibited such deduction. The copy of said order is attached herewith.</div>
<div>Therefore against said order u/s. 250 and u/s. 201(1) and 201(1A), we prefer to file appeal before ITAT and furnished facts of the case along with said appeal along with relevant documentary evidences and we demand the withdrawal of the same from your honour by allowing our appeal on the basis of grounds and evidences furnished by us. &#8220;</div>
<div><i>ITA No. 1011/Ahd/<span class="researchdochighlight">2026</span> (A.Y. 2016-17)</i></div>
<div><b>3. </b>The brief facts of the case are that the assessee, State Bank of India Currency Administration Cell, Gandhinagar, was subjected to proceedings under section 201(1) and 201(1A) of the Income-tax Act, 1961 (&#8220;the Act&#8221;) the assessee on the ground that it had failed to deduct tax at source under section 192 of the Act on Leave Fare Concession/Leave Travel Concession (LFC/LTC) granted to certain employees who had undertaken journeys involving a foreign leg during the financial year relevant to Assessment Year 2016-17. During the course of assessment proceedings, the Assessing Officer observed that exemption under section 10(5) of the Act read with Rule 2B of the Income Tax Rules is available only in respect of travel within India and once the employee undertakes travel involving a foreign destination, the exemption ceases to apply. The Assessing Officer relied upon the judgment of the Hon&#8217;ble Supreme Court in Civil Appeal No. 8181 of 2022 dated 04.11.2022 in the case of <i>State Bank of India</i> v. <i>Asstt.</i> (SC)/[2022] 449 ITR 192 (SC), wherein the Hon&#8217;ble Apex Court held that LTC exemption is restricted only to travel from one place in India to another place in India and the moment the journey involves a foreign leg, the exemption under section 10(5) is not available.</div>
<div><b>4. </b>The assessee before the Assessing Officer contended that the designated place of travel of employees was within India and reimbursement was restricted only to the eligible fare relatable to Indian travel in accordance with Rule 2B of the Rules. It was further contended that there was no express statutory prohibition against an incidental foreign leg in the course of travel and the bank had acted under a bona fide belief based on prevailing industry practice, IBA guidelines and judicial precedents. The assessee also relied upon interim orders passed by the Hon&#8217;ble Madras High Court in the case of All India State Bank Officers Federation v. State Bank of India, wherein the Hon&#8217;ble High Court had specifically directed that LFC reimbursement would not amount to income for the purpose of deduction of tax at source and further clarified that in case the writ petition failed, the liability to pay tax would be on the employees. The assessee submitted that during the subsistence of such interim judicial directions, it was legally restrained from deducting tax at source and any contrary action would have amounted to disobedience of binding judicial orders.</div>
<div><b>5. </b>The Assessing Officer, however, rejected the submissions of the assessee and held that in view of the final judgment of the Hon&#8217;ble Supreme Court dated 04.11.2022, the issue had attained finality against the assessee. The Assessing Officer held that once the employees undertook travel involving a foreign leg, the reimbursement became taxable salary and consequently the assessee was under a statutory obligation under section 192 to deduct tax at source. Accordingly, the assessee was treated as an assessee in default under section 201(1) and demand along with interest under section 201(1A) was raised.</div>
<div><b>6. </b>Aggrieved by the order of the Assessing Officer, the assessee preferred appeal before the learned CIT(Appeals). The learned CIT(Appeals) passed an order examining the provisions of section 10(5), Rule 2B and the judgment of the Hon&#8217;ble Supreme Court in the case of <i>State Bank of India</i> v. <i>ACIT (</i>supra). The learned CIT(Appeals) observed that a conjoint reading of section 10(5) and Rule 2B clearly establishes that exemption is admissible only where travel is undertaken from one place in India to another place in India by the shortest route. The learned CIT(Appeals) held that the moment a foreign leg is involved, the travel ceases to qualify as travel within India and therefore falls outside the scope of exemption under section 10(5) of the Act. The learned CIT(Appeals) reproduced in detail the findings of the Hon&#8217;ble Supreme Court, particularly the observations that LTC is intended to promote domestic travel within India and that foreign travel frustrates the very object of the scheme.</div>
<div><b>7. </b>The learned CIT(Appeals) further analysed the sequence of judicial proceedings before the Hon&#8217;ble Madras High Court and the Hon&#8217;ble Supreme Court. The learned CIT(Appeals) observed that although interim protection had been granted by the Hon&#8217;ble Madras High Court at various stages, there existed certain periods during which no stay operated and during such periods the assessee ought to have deducted tax at source or recovered the amount from employees. The learned CIT(Appeals) held that the obligation to deduct tax is distinct from recovery of tax and once the legal position stood clarified by the Hon&#8217;ble Supreme Court, the assessee could not avoid the consequences under section 201(1) and 201(1A). Reliance was also placed by the learned CIT(Appeals) on the decision of the Chennai Bench of the Tribunal in <i>State Bank of India, Chennai</i> v. <i>ACIT</i> [IT Appeal No.1465 (Chny) of 2024, dated 27-6-2025], wherein the Tribunal had upheld the action of the Department for periods during which no active stay operated. Accordingly, the learned CIT(Appeals) confirmed the action of the Assessing Officer in treating the assessee as an assessee in default under section 201(1) and in levying consequential interest under section 201(1A), though directions were issued for staying recovery till disposal of proceedings before higher judicial forums and for rectification of computational errors, if any.</div>
<div><b>8. </b>The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee.</div>
<div><b>9. </b>We have heard the rival submissions and perused the material available on record. The short controversy before us is not with regard to the merits of exemption under section 10(5) of the Act, which now admittedly stands concluded against the assessee by the judgment of the Hon&#8217;ble Supreme Court in <i>State Bank of India (supra)</i>.</div>
<div><b>10. </b>The limited issue before us is whether, in the peculiar facts of the present case, the assessee can be treated as an assessee in default under section 201(1) of the Act and consequently saddled with interest liability under section 201(1A) for non-deduction of tax at source during the period when binding interim judicial directions of the Hon&#8217;ble Madras High Court were operating.</div>
<div><b>11. </b>We find that this issue is now squarely covered in favour of the assessee by the decision of the Coordinate Bench of <span class="researchdochighlight">Ahmedabad</span> Tribunal in the case of <i>State Bank of India Bhavnagar Para Branch</i> v. <i>ITO </i> (<span class="researchdochighlight">Ahmedabad</span> &#8211; <span class="researchdochighlight">Trib</span>.). The Coordinate Bench, after considering the judgment of the Hon&#8217;ble Supreme Court, the interim orders of the Hon&#8217;ble Madras High Court, the decision of the Kerala High Court and the Agra Bench of the Tribunal, held that the assessee-bank could not be treated as an assessee in default under section 201(1) for the relevant period.</div>
<div><b>12. </b>The relevant observations of the Coordinate Bench are reproduced below:</div>
<div>&#8220;The contention of the assessee has consistently been that during the year under consideration, it was bound by the interim orders passed by the Hon &#8216;ble Madras High Court in All India State Bank Officers Federation v. State Bank of India 447ITR 559 (Madras), wherein vide order dated 16.02.2015 it was specifically clarified that the LFC payments would not amount to income so as to enable deduction of tax at source and further that if the writ petition was ultimately dismissed, the employees would be liable to pay tax. The assessee has submitted that in view of such binding judicial directions, it could not have deducted tax at source and any such deduction would have amounted to disobedience of the order of the Hon &#8216;ble High Court. &#8220;</div>
<div>&#8220;We find considerable merit in the aforesaid contention of the assessee. The interim directions of the Hon&#8217;ble Madras High Court were in force during the relevant previous year and the assessee, being a party to the proceedings, was duty bound to comply with the same. The obligation under section 192 of the Act to deduct tax at source cannot be read in isolation and must yield to binding judicial orders. Therefore, the failure to deduct tax in such circumstances cannot be equated with a default contemplated under section 201(1) of the Act. &#8220;</div>
<div><b>13. </b>The Coordinate Bench further relied upon the decision of the Agra Bench of the Tribunal in State Bank of India v. CIT(Appeals) and the judgment of the Hon&#8217;ble Kerala High Court in State Bank of India v. CIT. The findings of the Hon&#8217;ble Kerala High Court, as reproduced by the Coordinate Bench, are relevant and are reproduced below:</div>
<div>&#8220;It is only when the appellant-assessee, after having a liability to deduct tax, fails to do so, the question of invoking Section 201 of the Act and treating it as an &#8216;assessee in default&#8217; arises. Here, the Madras High Court found, prima facie, that the amount paid would not be the income of a payee so as to deduct tax. Therefore, we are of the opinion that the provisions of Section 201(1) of the Act are not attracted to the case at hand. &#8220;</div>
<div>&#8220;The appellant-assessee was under an obligation not to deduct tax at source and therefore, the assessee could not be held to be assessee in-default for non-deduction of tax at source on impugned LFC payments. &#8220;</div>
<div><b>14. </b>The <span class="researchdochighlight">Ahmedabad</span> Bench thereafter held as under:</div>
<div>&#8220;In the present case also, the facts are materially identical. The assessee was operating under the binding interim directions of the Hon &#8216;ble Madras High Court during the relevant period and therefore could not have deducted tax at source. The subsequent decision of the Hon&#8217;ble Supreme Court, though settling the issue on merits, cannot retrospectively fasten liability under section 201(1) of the Act for a period during which the assessee was acting in compliance with judicial orders. &#8220;</div>
<div>&#8220;We also find force in the argument of the assessee that the scheme of section 201 of the Act itself contemplates that a person can be treated as an assessee in default only when there is a failure to deduct tax in spite of a legal obligation to do so. In the present case, such legal obligation stood eclipsed by the interim directions of the Hon &#8216;ble High Court. &#8220;</div>
<div>&#8220;In view of the above discussion, respectfully following the decision of the Hon&#8217;ble Kerala High Court in State Bank of India (<i>supra</i>) and the decision of the Co-ordinate Bench in ITA No.514/Agr/2024, we hold that the assessee cannot be treated as an assessee in default under section 201(1) of the Act for the impugned period. Consequently, the interest charged under section 201(1A) also does not survive. &#8220;</div>
<div><b>15. </b>We find that the facts of the present case are materially identical to the facts before the <span class="researchdochighlight">Ahmedabad</span> Bench. During the relevant assessment year, the assessee-bank was operating under binding interim directions of the Hon&#8217;ble Madras High Court specifically clarifying that LFC payments would not constitute income for TDS purposes. Therefore, the assessee was legally bound to comply with such judicial directions and any deduction of tax contrary thereto would have exposed the assessee to proceedings for contempt of court. In such circumstances, the failure to deduct tax at source cannot be treated as a default contemplated under section 201(1) of the Act.</div>
<div><b>16. </b>Respectfully following the decision of the Coordinate Bench of <span class="researchdochighlight">Ahmedabad</span> Tribunal in <i>State Bank of India Bhavnagar Para Branch (supra)</i>, the decision of the Hon&#8217;ble Kerala High Court in <i>State Bank of India</i> v. <i>CIT </i><a id="anchor_10199.019515022368"></a> (Kerala) and the decision of the Agra Bench of the Tribunal in <i>State Bank of India</i> v. <i>CIT (Appeals) </i><a id="anchor_90343.94486306842"></a>[2025]  (Agra &#8211; <span class="researchdochighlight">Trib</span>.), we hold that the assessee cannot be treated as an assessee in default under section 201(1) of the Act for the impugned period. Consequently, the interest levied under section 201(1A) also does not survive.</div>
<div><b>17. </b>Accordingly, the Assessing Officer is directed to delete the demand raised under section 201(1) and interest levied under section 201(1A) of the Act.</div>
<div><b>18. </b>In the result, the appeal of the assessee is allowed.</div>
<div><b>19. </b>Since the facts in ITA No. 1011/Ahd/<span class="researchdochighlight">2026</span> are materially similar to facts in ITA No. 1044/Ahd/<span class="researchdochighlight">2026</span>, appeal of the assessee is allowed in ITA No. 1044/Ahd/<span class="researchdochighlight">2026</span> as well.</div>
<div><b>20. </b>In the combined result, both the appeals of the assessee are allowed.</div>
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		<title>No Under-Reporting Penalty Attracted When Reassessed Income Matches Return Filed Under Section 148</title>
		<link>https://www.taxheal.com/deputy-commissioner-of-income-tax.html</link>
		
		<dc:creator><![CDATA[Ashwani Kumar]]></dc:creator>
		<pubDate>Sat, 30 May 2026 05:06:16 +0000</pubDate>
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		<guid isPermaLink="false">https://www.taxheal.com/?p=132213</guid>

					<description><![CDATA[<p>No Under-Reporting Penalty Attracted When Reassessed Income Matches Return Filed Under Section 148 Issue Whether a penalty for under-reporting or misreporting of income under Section 270A can be sustained when the final reassessed income under Section 147 perfectly matches the income declared by the assessee in response to a Section 148 notice, and where the… <span class="read-more"><a href="https://www.taxheal.com/deputy-commissioner-of-income-tax.html">Read More &#187;</a></span></p>
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<p data-path-to-node="0"><strong>No Under-Reporting Penalty Attracted When Reassessed Income Matches Return Filed Under Section 148</strong></p>
<h2 data-path-to-node="1">Issue</h2>
<p data-path-to-node="2">Whether a penalty for under-reporting or misreporting of income under Section 270A can be sustained when the final reassessed income under Section 147 perfectly matches the income declared by the assessee in response to a Section 148 notice, and where the omission in the original return was due to a bona fide belief regarding tax-exempt agricultural land transactions.</p>
<h2 data-path-to-node="4">Facts</h2>
<ul data-path-to-node="5">
<li>
<p data-path-to-node="5,0,0"><b data-path-to-node="5,0,0" data-index-in-node="0">Original Filing:</b> The assessee, an individual, initially filed a regular return of income for the Assessment Year 2020-21 declaring a total income of ₹22.42 lakhs.</p>
</li>
<li>
<p data-path-to-node="5,1,0"><b data-path-to-node="5,1,0" data-index-in-node="0">The Omission:</b> Following a department search, it was discovered that the assessee had sold a parcel of agricultural land for ₹85 lakhs without offering the resulting capital gains to tax.</p>
</li>
<li>
<p data-path-to-node="5,2,0"><b data-path-to-node="5,2,0" data-index-in-node="0">Reopening of Assessment:</b> The income tax department reopened the case under Section 147 and served a notice under Section 148 upon the assessee.</p>
</li>
<li>
<p data-path-to-node="5,3,0"><b data-path-to-node="5,3,0" data-index-in-node="0">Response to Notice:</b> In direct response to the Section 148 notice, the assessee filed a new return declaring an enhanced total income of approximately ₹30.11 lakhs, which fully included a short-term capital gain of about ₹7.90 lakhs from the land sale, with all due taxes paid.</p>
</li>
<li>
<p data-path-to-node="5,4,0"><b data-path-to-node="5,4,0" data-index-in-node="0">Assessment Conclusion:</b> The Assessing Officer (AO) completed the reassessment under Section 147, entirely accepting the revised income figure submitted by the assessee in the Section 148 return.</p>
</li>
<li>
<p data-path-to-node="5,5,0"><b data-path-to-node="5,5,0" data-index-in-node="0">Penalty Imposed:</b> Despite accepting the return, the AO treated the difference between the original income (under Section 143(1)) and the final reassessed income as under-reported income due to misreporting. Accordingly, the AO levied a 200% penalty on the tax amount under Section 270A(9).</p>
</li>
<li>
<p data-path-to-node="5,6,0"><b data-path-to-node="5,6,0" data-index-in-node="0">Assessee&#8217;s Explanation:</b> The assessee explained that the initial non-disclosure was based on a bona fide belief that selling dry agricultural land to reinvest in another agricultural plot did not attract income tax.</p>
</li>
</ul>
<h2 data-path-to-node="7">Decision</h2>
<ul data-path-to-node="8">
<li>
<p data-path-to-node="8,0,0"><b data-path-to-node="8,0,0" data-index-in-node="0">No Differential, No Under-Reporting:</b> The appellate authority held that the concept of under-reporting must be evaluated by comparing the income assessed by the AO against the return filed specifically in response to the Section 148 notice. Since there was zero difference between the reassessed income and the Section 148 returned income, the statutory baseline for under-reporting did not exist.</p>
</li>
<li>
<p data-path-to-node="8,1,0"><b data-path-to-node="8,1,0" data-index-in-node="0">Bona Fide Exception Apparent:</b> Under Section 270A, under-reported income explicitly excludes amounts where the taxpayer offers a bona fide explanation and discloses all material facts. The panel found the assessee&#8217;s explanation regarding agricultural land status to be completely bona fide.</p>
</li>
<li>
<p data-path-to-node="8,2,0"><b data-path-to-node="8,2,0" data-index-in-node="0">Penalty Deleted:</b> Because the AO accepted the returned figures and the explanation was legitimate, the court ruled that the AO should not have levied the penalty. The Section 270A penalty was officially deleted.</p>
</li>
</ul>
<h2 data-path-to-node="10">Key Takeaways</h2>
<ul data-path-to-node="11">
<li>
<p data-path-to-node="11,0,0"><b data-path-to-node="11,0,0" data-index-in-node="0">The Section 148 Baseline Rule:</b> For reassessment proceedings, the benchmark for measuring &#8220;under-reporting&#8221; shifts to the return filed in response to the Section 148 notice. If the AO accepts that specific return without further additions, a penalty under Section 270A cannot be mechanically triggered.</p>
</li>
<li>
<p data-path-to-node="11,1,0"><b data-path-to-node="11,1,0" data-index-in-node="0">Protection via Bona Fide Explanations:</b> A subjective error or misconception of law (such as confusing the taxability rules of rural vs. dry agricultural land transitions) will not be penalized as deliberate misreporting if the taxpayer acts in good faith, cooperates with the reopening notice, pays the tax, and fully discloses the material facts.</p>
</li>
<li>
<p data-path-to-node="11,2,0"><b data-path-to-node="11,2,0" data-index-in-node="0">No Automated Penalty Application:</b> Tax authorities cannot use reassessment entry points to automatically enforce the maximum 200% penalty rate under the guise of misreporting without establishing a deliberate intent to deceive or a secondary discrepancy in the reassessment filing itself.</p>
</li>
</ul>
<div id="111070000000000011" style="text-align: center;">IN THE ITAT <span class="researchdochighlight">HYDERABAD</span> BENCH &#8216;SMC&#8217;</div>
<div id="" style="text-align: center;">Ratna Show Reddy Singareddy</div>
<div style="text-align: center;">v.</div>
<div id="" style="text-align: center;">Deputy Commissioner of Income-tax</div>
<div id="dbs_judge" style="text-align: center;"><span id="111170000000056962">VIJAY PAL RAO</span>, Vice President<br />
and <span id="111170000000124978">MANJUNATHA G</span>, Accountant Member</div>
<div style="text-align: center;">I.T.A.No. 42 (Hyd) OF <span class="researchdochighlight">2026</span><br />
[Assessment year 2020-21]</div>
<div style="text-align: center;">MAY  6, <span class="researchdochighlight">2026</span></div>
</div>
<div></div>
<div>
<div id="digest">
<div><b>Vamseedhar</b>, C.A.<i> for the Appellant. </i><b>Mookambikeyan S.</b>, Sr. AR<i> for the Respondent.</i></div>
</div>
<div id="caseOrder">
<div>
<div>ORDER</div>
<div></div>
<div><b>Manjunatha G., Accountant Member. </b>&#8211; This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals) &#8211; <span class="researchdochighlight">Hyderabad</span> -11, (for short &#8220;Ld. CIT(A)), dated 14.11.2025, pertaining to the assessment year 2020-21.</div>
<div><b>2. </b>The brief facts of the case are that, the assessee is an individual and filed his original return of income for A.Y. 2020-21 on 09.01.2021, admitting the total income of Rs.22,42,400/-. A search and seizure operation under section 132 of the Income-tax Act, 1961 was conducted in the group cases of M/s. Bala Vikasa Social Service Society on 15.03.2023 and as a part of search, the case of the assessee was also covered. During the course of search, it was found that, the assessee had sold immovable property for a consideration of Rs.85,00,000/-, however, has not offered capital gains to tax. Consequent to search, the assessment has been reopened under section 147 of the Act, and during the course of assessment proceedings, the A.O. called upon the assessee to file relevant details of computation of capital gain, if any, for sale of property. The assessee filed the return of income in response to notice under section 148 of the Act, on 26.07.2024, declaring total income of Rs.30,11,280/-, which includes short-term capital gain of Rs.7,90,475/- from sale of property. The A.O., after considering relevant submissions of the assessee and also taking note of the return of income filed by the assessee, completed assessment under section 147 of the Act, on 07.02.2025 and accepted the income declared by the assessee. The A.O. had also initiated penalty proceedings under section 270A of the Act, for under-reporting of income, is in consequence of misreporting thereof.</div>
<div><b>3. </b>During the penalty proceedings, the A.O. called upon the assessee to explain as to why the penalty shall not be levied for under-reporting of income, is in consequence of misreporting of income of Rs.7,90,475/- in respect of short-term capital gain offered in the return of income filed in response to notice issued under section 148 of the Act. In response, the assessee submitted his explanation on 17.02.2025 and on 21.07.2025 and claimed that, he had sold dry agricultural land for a consideration of Rs.85,00,000/-and also purchased another agricultural land from the sale consideration, and on the bonafide belief that sale of agricultural land and purchase of another agricultural land does not attract tax. The assessee further submitted that, he has also admitted capital gain for sale of property in response to notice under section 148 of the Act, and therefore, it cannot be said that the assessee has under-reported income, is in consequence of misreporting of income.</div>
<div><b>4. </b>The A.O., after considering relevant submissions of the assessee and also taking note of the provisions of section 270A(9) of the Act, observed that, there is a difference between income computed in the assessment order passed under section 147 r.w.s. 143(3) of the Act, and the income determined in the order passed under section 143(1) of the Act, and the difference in amount of income admitted by the assessee falls under the category of under-reporting of income, and further, the same is liable for penalty under section 270A(9) of the Act, for under-reporting of income, is in consequence of misreporting of income, and therefore, rejected the explanation of the assessee and levied penalty of Rs.4,79,780/-, which is 200% of the amount of tax payable on under-reporting of income.</div>
<div><b>5. </b>Aggrieved by the penalty order, the assessee preferred appeal before the learned CIT(A) and challenged levy of penalty under section 270A(9) of the Act. Before the learned CIT(A), the assessee submitted that, he was under the bona fide belief that sale of agricultural land and purchase of another agricultural land, no tax is leviable and accordingly not has disclosed the transactions in the return of income filed under section 139(1) of the Act. The assessee further submitted that, he has voluntarily admitted short-term capital gains and paid taxes in the return of income filed in response to notice under section 148 of the Act, and therefore, the case of the assessee cannot be considered under section 270A(9) of the Act. The learned CIT(A), after considering the submissions of the assessee and also taking note of provisions of section 270A(9) of the Act, observed that, the assessee has under-reported income, is in consequence of misreporting of income by misrepresentation or suppression of facts which is evident from the relevant return of income filed by the assessee under section 139 of the Act, and return of income filed in response to notice under section 148 of the Act. Further, it is also pertinent to note that the assessee has not offered the short-term capital gain voluntarily, but due to the very fact that the sale of agricultural land was unearthed during the course of search operation and the search had not taken place, the assessee would not have disclosed capital gains. Therefore, it is a clear case of under-reporting of income, is in consequence of misreporting thereof, and therefore, the A.O. has rightly levied penalty under section 270A(9) of the Act, and thus, rejected the explanation of the assessee and upheld the penalty levied by the A.O.</div>
<div><b>6. </b>Aggrieved by the order of the learned CIT(A), the assessee is in appeal before the Tribunal.</div>
<div><b>7. </b>The learned counsel for the assessee, Shri Vamseedhar, C.A. submitted that, the learned CIT(A) erred in sustaining the penalty levied under section 270A(9) of the Act, even though there is no difference between the returned income and assessed income, and unless there is a difference in the returned income and assessed income, the concept of under-reporting of income cannot be applied. The learned counsel for the assessee further submitted that, the assessee had sold agricultural land and had also purchased another agricultural land, and the assessee was under the bona fide belief that the sale of agricultural land does not attract capital gains. However, upon noticing the fact that the assessee is liable to pay tax on sale of land, he had disclosed capital gains in response to notice under section 148 of the Act, and also paid taxes. Therefore, the A.O. was not right in invoking the provisions of section 270A and levying penalty for misreporting of income. The learned CIT(A), without appreciating the relevant facts, simply upheld the penalty levied by the A.O. Therefore, he submitted that the order of the learned CIT(A) should be set aside and the penalty levied by the A.O. should be deleted.</div>
<div><b>8. </b>The learned Senior A.R. for the Revenue, Shri S. Mookambikeyan, on the other hand, supporting the order of the learned CIT(A), submitted that, it is a clear case of under-reporting of income, is in consequence of misreporting of income, which is evident from the return of income filed under section 139 of the Act, and the revised return filed in response to notice under section 148 of the Act. The assessee has not reported capital gains in the original return of income. Although the assessee has reported capital gains in the revised return filed in response to notice under section 148 of the Act, but fact remains that there is a difference between determined under section 143(1) of the Act, and income assessed, which falls under sub-section (3) of section 270A of the Act. Since the assessee has misrepresented or suppressed the facts with regard to the capital gains, the A.O. has rightly invoked section 270A(9) of the Act. Thus, there is no merit in the arguments of the assessee and thus, the appeal filed by the assessee should be dismissed.</div>
<div><b>9. </b>We have heard both parties, perused the material available on record, and had gone through the orders of the authorities below. There is no dispute with regard to the fact that the assessee has not disclosed the capital gains derived on sale of agricultural land in the return of income filed under section 139 of the Act. It is also not in dispute that the assessee has disclosed the capital gains derived from sale of agricultural land in the return of income filed in response to notice issued under section 148 of the Act, and paid relevant taxes. The A.O. completed the assessment and accepted the return filed in response to notice under section 148 of the Act. Therefore, it is necessary for us to decide the issue of levy of penalty under section 270A(9) of the Act, in light of the above facts and also the arguments of the learned counsel for the assessee.</div>
<div><b>10. </b>The A.O. invoked provisions of Section 270A(9) of the Act, and levied 200% penalty on tax sought to be evaded in respect of underreporting of income. The amount of under reported income has been explained under sub-section (3) of Section 270A of the Act, and according to sub-section (3), in a case where the income has been assessed for the first time, if return has been furnished, the difference, if any, between the amount of income assessed and the amount of income determined under Section 143(1) of the Act, shall be treated as under-reported income. In the present case, there is no difference between the income assessed for the first time and the income determined as per section 143(3) of the Act, because there was no regular assessment under section 143(3) of the Act. However, there is a difference between the income assessed by the A.O. in the order passed under Section 143(3) r.w.s. 147 of the Act, and the income determined under Section 143(1) of the Act. However, there is no difference between the income returned by the assessee in response to notice under Section 148 of the Act and the income assessed by the A.O. Therefore, the concept of under-reporting of income has to be understood in the context of return of income filed in response to notice under section 148 of the Act, and the income assessed by the A.O., and if we consider the income assessed by the A.O. and the income returned by the assessee, then there is no difference, and therefore, in our considered view, the concept of under-reporting of income for the purpose of section 270A of the Act, does not arise. Further, insofar as the merits of the case are concerned, the assessee was under the bona fide belief that the sale of dry agricultural land and purchase of another agricultural land does not attract tax, and this fact has been explained to the A.O. Therefore, once the amount of income in respect of which the assessee offers explanation and the A.O. is satisfied that the explanation is bona fide and the assessee has disclosed all the material facts, then for the purpose of section 270A of the Act, the under-reporting of income shall not include the income on which the explanation is offered by the assessee. Since the explanation of the assessee with regard to the sale of agricultural land is bona fide, in our considered view, the A.O. ought to have accepted the explanation of the assessee and not levied penalty under section 270A of the Act. The learned CIT(A), without appreciating the relevant facts, simply upheld the penalty levied by the A.O. Thus, we set aside the order of the learned CIT(A) and direct the A.O. to delete the penalty levied under section 270A of the Act.</div>
<div><b>11. </b>In the result, the appeal of the assessee is allowed.</div>
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