NARENDRA KUMAR GUPTA,REWA vs. INCOME TAX OFFICER WARD -1, REWA

This is a set of two Appeals by the Assessee directed against his assessment dated 25/09/2017 under section 143(3) and the levy of penalty u/s. 271(1)(c) of the Income Tax Act, 1961 ('the Act' hereinafter), both for assessment year 2015-16, on the confirmation thereof by the Commissioner of Income Tax (Appeals)-1, Jabalpur (‘CIT(A)’ for short) vide his Orders dated 01/10/2019 and 29/11/2019 respectively.

At the very outset, it was submitted by Sh. Usrethe, the ld. counsel for the assessee, that the assessee has applied for settlement of the dispute under the ‘Vivad Se Viswas Scheme, 2019’, and has in fact also received Form 3, i.e., the certificate under the Direct Tax Vivad Se Viswas Act, 2020 (‘DTVsV Act’, hereinafter) read with the relevant Rule, signifying its acceptance, for one of the two appeals, being the penalty appeal (in ITA 13/JB/2020), even as stated in the 1