NEETA PRASHANT GODSE,PUNE vs. INCOME TAX OFFICER WARD 1, SATARA

The sole grievance of the assessee is against the levy of penalty u/s 271(1)(c) of the Act at Rs. 63,64,762/-.

We heard the rival contention and perused the records placed before us. We note that the assessee is an individual and income of Rs. 6,06,610/- declared in the income tax return. Subsequently assessment proceedings u/s 147 r.w.s 144 of the Act were carried out and addition made for unexplained money u/s 69A of the Act at Rs. 1,80,27,960/- and

In the course of hearing ld. Counsel for the assessee referring to paper book page In the course of hearing ld. Counsel for the assessee referring to paper book page In the course of hearing ld. Counsel for the assessee referring to paper book page In the course of hearing ld. Counsel for the assessee referring to paper book page 29 to 34 submitted that submitted that the appeal challenging the quantum addition has already been the appeal challenging the quantum addition has already been the appeal challenging the quantum addition has already been restored by this Hon’ble Tribunal by this Hon’ble Tribunal to the file of ld. CIT(A) for afresh adjudication vide f ld. CIT(A) for afresh adjudication vide f ld. CIT(A) for afresh adjudication vide ITA No. 2150/Pun/2025 dated 25.03.2026. ITA No. 2150/Pun/2025 dated 25.03.2026. Under these given facts and circumsta Under these given facts and circumstances nces since the penalty is depen since the penalty is dependent upon the addition and that grounds challenging the upon the addition and that grounds challenging the upon the addition and that grounds challenging the quantum addition have already been restored to th quantum addition have already been restored to th quantum addition have already been restored to the file of ld. CIT(A) for afresh e file of ld. CIT(A) for afresh adjudication therefore therefore the grounds raised in the present appeal challenging the levy of the grounds raised in the present appeal challenging the levy of the grounds raised in the present appeal challenging the levy of penalty u/s 271(1)(c) of the Act are also restore penalty u/s 271(1)(c) of the Act are also restored to the file of Ld. CIT(A) for afresh to the file of Ld. CIT(A) for afresh adjudication along with quantum addition. adjudication along with quantum addition. Needless to mention that the ess to mention that the ld. CIT(A) CIT(A) shall afford proper opportunity to the assessee. Further, we direct the assessee shall afford proper opportunity to the assessee. Further, we direct the assessee shall afford proper opportunity to the assessee. Further, we direct the assessee shall afford proper opportunity to the assessee. Further, we direct the assessee to remain cooperative in furnishing the details called for by the ld. CIT(A). to remain cooperative in furnishing the details called for by the ld. CIT(A). to remain cooperative in furnishing the details called for by the ld. CIT(A). to remain cooperative in furnishing the details called for by the ld. CIT(A). Thus finding of ld. CIT(A) is set aside and effective ground inding of ld. CIT(A) is set aside and effective ground inding of ld. CIT(A) is set aside and effective grounds of appeal raised s of appeal raised by the assessee in the instant appeal in the instant appeal are allowed for statistical purposes. are allowed for statistical purposes.

In the result the appeal filed by the assessee is allowed for statistical In the result the appeal filed by the assessee is allowed for statistical In the result the appeal filed by the assessee is allowed for statistical In the result the appeal filed by the assessee is allowed for statistical purposes.