Actor and politician Vijay has filed an appeal before a Division Bench of the Madras High Court against a single-judge's recent judgment upholding a ₹1.5 crore income tax penalty imposed on him.

Though the appeal was filed in March 2026, it is yet to be processed for listing.

The appeal was filed after single-judge Justice Senthilkumar Ramamoorthy dismissed Vijay’s petition, holding that the penalty order by the Income Tax Department was within the prescribed limitation period under the Income Tax Act.

The case arose from Vijay’s assessment for the financial year 2015–16 (assessment year 2016–17), which followed a search conducted by the Income Tax Department on September 30, 2015.

During the search, Vijay admitted in a sworn statement that he had received ₹15 crore in cash as remuneration, in addition to ₹16 crore received through banking channels. This undisclosed income was subsequently included in his return.

The assessment proceedings also examined an expenditure head titled “Release & Rasigar Mandram Expenses,” under which Vijay claimed ₹2.92 crore. According to his authorised representative, ₹2 crore was paid directly by the film’s producer to fan club members across Tamil Nadu and Puducherry while ₹92.44 lakh was paid in cash by Vijay.

The Assessing Officer disallowed the ₹2 crore component for lack of proof and allowed only part of the cash expenditure. On appeal, the Commissioner of Income Tax (Appeals) granted partial relief, and the Income Tax Appellate Tribunal ultimately allowed 50% of the total expenditure.

Separately, penalty proceedings were initiated under Section 271AAB, which deals with penalties in search cases. The department imposed a penalty of ₹1.5 crore—10% of the admitted undisclosed income of ₹15 crore.

Before the High Court's single-judge, Vijay confined his challenge solely to limitation. He argued that the penalty order dated June 30, 2022 was time-barred under Section 275(1)(c), which prescribes a shorter six-month limitation period for “any other case.”

The single-judge rejected Vijay’s contention and upheld the penalty order.

The Court noted that the ITAT order was issued on December 22, 2021, and the six-month period expired on June 30, 2022—the very date on which the penalty order was passed.

It concluded that the order was within limitation and found no infirmity warranting interference.

Vijay has now challenged this decision before Division Bench.