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Facts
The assessee filed appeals challenging penalty orders for AY 2015-16 and 2016-17. During the pendency of the appeals, the assessee filed an application under the Direct Tax Vivad se Vishwas Scheme, 2024.
Held
The Tribunal noted that the assessee had filed an application under the Vivad se Vishwas Scheme and the scheme's form 4 was issued. Consequently, the appeals were dismissed as infructuous.
Key Issues
Whether the appeals are infructuous due to the assessee opting for the Vivad se Vishwas Scheme.
Sections Cited
271(1)(c)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘B’ BENCH : BANGALORE
Before: SHRI LAXMI PRASAD SAHU & SHRI SOUNDARARAJAN K.
ORDER PER BENCH Both these appeals are filed by the assessee challenging the penalty orders of the Ld.ITO, Ward – 5(3)(1), Bangalore both dated 25/02/2020 in respect of the A.Ys. 2015-16 and 2016-17.
In both the years, the only dispute is with regard to penalty imposed u/s. 271(1)(c) of the Act which was confirmed by the Ld.CIT(A). when the appeal is pending before the Tribunal, the assessee had informed on & 2416/Bang/2024 23/01/2025 that he had filed an application under the Direct Tax Vivad se Vishwas Scheme, 2024 by filing form no. 1 on 20/12/2024. The assessee also filed the copies of form no. 1 filed in this regard. Subsequently, the assessee not appeared before this Tribunal. Therefore we directed the Ld.DR on 01/09/2025 to find out the status of the application filed under the said scheme. The Ld.DR at the time of hearing on 04/09/2025, filed the copies of the form 4 issued on 28/04/2025 and 29/04/2025 in respect of the A.Ys. 2015-16 and 2016-17.
Recording the said form 4, we dismiss the appeals filed by the assessee as infructous.
In the result, both the appeals filed by the assessee are dismissed as infructous.
Order pronounced in the open court on 04th September, 2025.