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Income Tax Appellate Tribunal, [ DELHI BENCH “G”: NEW DELHI ]
Before: SHRI AMIT SHUKLA & SHRI PRASHANT MAHARISHI
O R D E R PER PRASHANT MAHARISHI, A.M. :
This appeal is filed by the assessee in against the order passed by the ld. Commissioner of Income Tax (Appeals)–1, New Delhi, dated 30th July, 2018, wherein the penalty levied by the ld. Assessing Officer under Section 271(1)(c) of the Income Tax Act, 1961 (the Act) imposing a penalty of Rs. 59,27,620/- for furnishing inaccurate particulars of income and also concealing the particulars of income was confirmed.
The assessee has raised the following grounds of appeal:- “1. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in imposing penalty of Rs.59,27,620/- u/s 271(l)(c) and that too without assuming jurisdiction as per law and the impugned penalty order being illegal and void ab-initio and without observing the principles of natural justice.
2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in imposing penalty and passing the impugned penalty order and that too without recording the mandatory ‘satisfaction’ as per law and without levying a clear charge whether there was concealment of income or furnishing of inaccurate particulars and without the valid approval of Ld. JCIT. Page | 1
3. That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the action of Ld. AO in imposing penalty u/s 271(l)(c), is bad in law and against the facts and circumstances of the case.
That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in passing the impugned order and that too without considering the written submissions filed before Ld. CIT(A). 5. That the assessee craves the leave to add, alter or amend the grounds of appeal at any stage and all the grounds are without prejudice to each other. “