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Income Tax Appellate Tribunal, DELHI ‘E’ BENCH,
Before: SHRI AAKASH DEEP JAIN & SHRI N.K. BILLAIYA
PER N.K. BILLAIYA, ACCOUNTANT MEMBER:
The above captioned three separate appeals by the assessee are preferred against the order of the Commissioner of Income Tax [Appeals]- 12, New Delhi pertaining to A.Ys 2006-07, 2007-08 and 2009-10.
All the three appeals relate to the levy of penalty u/s 271(1)(c) of the Income-tax Act, 1961 [hereinafter referred to as 'The Act'].
3, We find that this Tribunal in & 799/DEL/2016 for Assessment Years 2006-07 and 2009-10 has restored the quantum appeals to the to the file of the ld. CITA.
Considering the fact that the quantum additions have been set aside to the file of the ld. CIT(A), we deem it proper to restore the issue relating to levy of penalty u/s 271(1)(c) of the Act to be decided afresh after deciding the quantum additions. Therefore, all the three appeals are restored to the file of the ld. CIT(A) with the direction to decide the levy of penalty u/s 271(1)(c) of the Act after deciding the quantum additions.
In the result, the appeals of the assessee in 8205 and 8206/DEL/2018 are allowed for statistical purposes.
The order is pronounced in the open court on 09.12.2021.