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Income Tax Appellate Tribunal, “D” BENCH, MUMBAI
Before: SHRI AMIT SHUKLA, JM & SHRI S. RIFAUR RAHMAN, AM
O R D E R
Per Amit Shukla, Judicial Member:
The aforesaid appeal has been filed by the assessee against the impugned order dated 17.08.2022, passed by National Faceless Appeal Centre (NFAC), Delhi in relation to penalty proceedings u/s 271(1)(c) for AY 2012-13. 2 Mr. Mayur P. Jain 2. Assessee is aggrieved by levy of penalty of Rs. 1,00,000/- made by AO and confirmed by Ld. CIT(A).
The facts in brief are that AO noted that assessee had shown loan from one of the party, Smt. Pistaben Sohanraj Sonigra. The addition was made by the AO on the ground that the said party is not showing the assessee as debtor for loan given to the assessee for Rs 1 lakh, whereas, the assessee has shown the same under the head ‘unsecured loan’. Though the assessee has filed the balance sheet, etc. of the said party showing that the loan was coming from earlier years, however, AO has still levied penalty of Rs. 1 Lakh and the same has been confirmed by the Ld. CIT (A) also.