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“penalty u/s 270A”

PenaltySection 270ASection 270A583 judgments

The decision most relied on for penalty u/s 270A is HCIL Arsspl Triveni (JV) v. ACIT ( (274 ITR 603), cited in 21 judgments on BharatTax.

Leading authorities on penalty u/s 270A

HCIL Arsspl Triveni (JV) v. ACIT (
274 ITR 603 · 2005 · High Court
21
citing judgments

An inaccurate claim made by the assessee cannot be treated as a case of giving inaccurate particulars of income for the purpose of imposing penalty.

GR Infraprojects Ltd. v. ACIT
158 Taxmann.com 80 · 2024 · High Court
11
citing judgments

Penalty under section 270A cannot be sustained without the Assessing Officer specifying the exact charge against the assessee, including which part of section 270A(9) is attracted. Immunity under section 270AA may be granted if the Assessing Officer fails to specify the relevant sub-clause of section 270A(9) or mechanically passes an order without considering the assessee's replies.

Judgments citing penalty u/s 270A

Soni and Brothers, Surat vs. ITO, Ward 2(3)(6), Surat

In the result, appeal of the assessee is allowed for statistical purposes

ITA 808/SRT/2024[2020-21]Status: DisposedITAT Surat22 Jan 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.807 & 808/Srt/2024 Assessment Year: (2020-21) (Physical Hearing) Soni & Brother, Vs. The Ito, H-29, New Sardar Market, Dumbhai Ward – 2(3)(6), Patia, Surat - 395010 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawfs6792H (Appellant) (Respondent) Appellant By Shri Ashish Bhoola, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 21/01/2025 Date Of Pronouncement 22/01/2025

Section 250Section 270A

appellant submitted during the first appellate proceedings. 2. Miscellaneous: (a) The learned Commissioner of Income-tax (Appeals) has erred in not deleting the penalty u/s 270A for undertaking reporting of income as the additions on the basis of which penalty was invoked was not warranted for in view of submission

Soni and Brothers, Surat vs. ITO, Ward 2(3)(6), Surat

In the result, appeal of the assessee is allowed for statistical purposes

ITA 807/SRT/2024[2020-21]Status: DisposedITAT Surat22 Jan 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.807 & 808/Srt/2024 Assessment Year: (2020-21) (Physical Hearing) Soni & Brother, Vs. The Ito, H-29, New Sardar Market, Dumbhai Ward – 2(3)(6), Patia, Surat - 395010 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawfs6792H (Appellant) (Respondent) Appellant By Shri Ashish Bhoola, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 21/01/2025 Date Of Pronouncement 22/01/2025

Section 250Section 270A

appellant submitted during the first appellate proceedings. 2. Miscellaneous: (a) The learned Commissioner of Income-tax (Appeals) has erred in not deleting the penalty u/s 270A for undertaking reporting of income as the additions on the basis of which penalty was invoked was not warranted for in view of submission

Mr. Nateshan Sampath, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1779/BANG/2024[2018-19]Status: DisposedITAT Bangalore22 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Sri Mahesh G., A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 148Section 250Section 270ASection 270A(8)Section 274

claimed cost of improvement of Rs.45,60,000/-, the assessee has failed to substantiate the claim of expenditure of cost of improvement, penalty u/s 270A(8) of the Act for under reporting of income in consequence of misreporting is initiated separately”. 3.1 The AO thereafter issued notice dated 28.2.2023 u/s ... year 2018-19 directing the Mr. Nateshan Sampath, Bangalore Page 3 of 12 assessee to show cause as to why an order imposing penalty u/s 270A of the Act shall not be passed for under reported income, which is in consequence of mis-reported income as per details given

Sri. Peter Paul Mariappa, Bangalore vs. The Income Tax Officer, Ward-5(3)(4), Bangalore

In the result, the appeal filed by the assessee is dismissed as withdrawn

ITA 2037/BANG/2024[2020-21]Status: DisposedITAT Bangalore16 Jan 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Ms. Sunaina Bhatia, Advocate
Section 270A

following grounds of appeal: “1. The orders of the authorities below in so far as levying penalty u/s 270A of the Act against the appellant are opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. 2. The learned CIT[A] is not justified in disposing ... circumstances of the appellant's case, the learned Assessment Unit ought to have exercised his discretion and refrained from imposing penalty u/s 270A of the Act under the facts and circumstances of the appellant's case. 6. The authorities below are not justified in levying penalty u/s.270A

M/S. Mono Steel (India) Ltd., Mumbai vs. The Dy. Commissioner of Income Tax, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 285/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad15 Jan 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mohit Balwani, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR
Section 270ASection 80

Learned CIT(A) has erred in law and on the facts of the case in confirming the action of learned AO in levying penalty u/s 270A of the Act amounting to Rs. 36,31,592/-. 3. In any case, the quantification of the penalty is erroneous and excessive

M/S. Mono Steel (India) Ltd., Mumbai vs. The Dy. Commissioner of Income Tax, Circle-2(1)(1), Ahmedabad

ITA 284/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad15 Jan 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mohit Balwani, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR
Section 270ASection 80

Learned CIT(A) has erred in law and on the facts of the case in confirming the action of learned AO in levying penalty u/s 270A of the Act amounting to Rs.36,31,592/-. 3. In any case, the quantification of the penalty is erroneous and excessive

Shahu Shikshan Prasarak Mandal, Latur vs. ACIT (Exmp.) Circle, Aurangabad

In the result, the appeal of the assessee is allowed for statistical

ITA 951/PUN/2024[2020-21]Status: DisposedITAT Pune15 Jan 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Suhas P. BoraFor Respondent: Shri Ajay Kumar Keshari
Section 10Section 12ASection 142(1)Section 143(3)Section 144BSection 56Section 57

total income. Since the assessee has made wrong claim_of deduction and_thereby under- reported his income to that extent, therefore penalty u/s 270A(2) is separately initiated. (Para No. 6.6 of Assessment Order dt. 21.09.2022, Sir, on the aforesaid issue, the assessee trust respectfully states as under: In order

Silver Oak Buildcon Pvt. Ltd., Pune vs. ACIT-6, Pune

In the result, the appeal filed by the assessee is allowed

ITA 2589/PUN/2024[2017-18]Status: DisposedITAT Pune15 Jan 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Miss Aarti ThakkarFor Respondent: Shri Arvind Desai, Addl. CIT-DR
Section 143(1)Section 143(2)Section 270ASection 36(1)(va)Section 43B

report, the non-inclusion of such service tax liability and belated payment of employees’ contribution to PF does not call for levy of penalty u/s 270A of the Act. 17. We find some force in the above arguments of the Ld. Counsel for the assessee. It is an admitted fact ... respectfully following the decisions cited (supra), we are of the considered opinion that it is not a fit case for levy of penalty u/s 270A of the Act. We, therefore, set aside the order of the Ld. CIT(A) / NFAC and direct the 14 Assessing Officer to cancel the penalty

Om Prakash, Gaya vs. Dc/Ac, Circle-1, Gaya

The appeal of the assessee is allowed for statistical purposes

ITA 31/PAT/2023[2017-18]Status: DisposedITAT Patna14 Jan 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.31/Pat/2023 Assessment Year: 2017-18 Om Prakash…………………….. ………...…..…………………....Appellant G. B. Road, Murarpur, Gaya – 823001. [Pan: Aocpp7508Q] Vs. Dc/Ac, Circle-1, Gaya………………….............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 09, 2025 Date Of Pronouncing The Order : January 14, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 06.05.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 215 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delay Was Not Intentional.. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Is Engaged In Retail Businesses & Service Sector & Filed Return Of Income On 31.03.2018 For The Assessment Year 2017-18 By Declaring A Total Income Of

Section 143(2)Section 143(3)Section 144Section 250Section 270A

addition made by the Assessing Officer in the assessment order passed u/s 143(3) of the Act but only challenged the initiation of penalty u/s 270A, 272A(1)(d) and 271B of the Act. Without going into any technicalities, in the interest of justice and fair play, we deem

Terai Fruits Company, Siliguri vs. Income Tax Officer, Ward-1(1), Siliguri

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

ITA 2099/KOL/2024[2018-19]Status: DisposedITAT Kolkata14 Jan 2025AY 2018-19

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 144BSection 147Section 148Section 250Section 270ASection 274Section 285B

penalty order was passed. The contention of the appellant cannot be accepted for the reason that for granting immunity from imposition of penalty u/s 270A, application shall be made in Form 68. In this connection, attention is drawn to the provisions of Rule 129, Income Tax Rules, 1962 which ... made in Form No. 68.]” Mere submission of appellant in writing instead of Form 68 cannot be reason for granting immunity from penalty u/s 270A. Since the appellant has not filed the requisite application for waiving of penalty as per provision of Section 270AA, the AO hence rightly levied penalty

Vedant Properties, Pune vs. ITO Ward 3(1) Pune, Pune

In the result, the appeal filed by the assessee is

ITA 2216/PUN/2024[2017-18]Status: DisposedITAT Pune10 Jan 2025AY 2017-18

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl. CIT-DR
Section 143(2)Section 270ASection 274

progress and hence, as the said expenditure was not claimed as a deduction in the year under consideration, the question of levy of penalty u/s 270A simply did not arise. 6) The appellant craves leave to add, alter, amend or delete any of the above grounds of appeal.” 5. Learned

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Sunil Kumar Sood, Panchkula

The appeal of the Revenue is dismissed

ITA 548/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh09 Jan 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl.CIT, Sr.DR
Section 118Section 143(2)Section 143(3)

surplus amount of Rs. 2,41,88,998 (Rs.4,32,59,600-Rs.1,90,70,602/-) as income of the assessee and penalty u/s 270A has been initiated. Decision: (a) Only issue is whether there is some capital gain or not. If yes, then what would be the year

Dy.Commissioner of Income Tax, Central, Circle-1, Aurangabad vs. Tapadiya Constructions Ltd, Aurangabad

In the result, appeal of the Revenue is partly allowed

ITA 976/PUN/2024[2019-20]Status: DisposedITAT Pune09 Jan 2025AY 2019-20

Bench: MS.ASHTA CHANDRA, JUDICIAL MEMBER AND DR.DIPAK P. RIPOTE (Accountant Member)

Section 132Section 250Section 271(1)(c)Section 271ASection 281A

proceedings u/s 132 of the Act is initiated, and on the other hand thesub-section (2) puts an embargo on imposing of penalty u/s 270A and u/s 271(1)(c) of the Act on suchundisclosed income falling within the realm of subsection (1). This clearly establishes the solitary domain ofsection ... income where the proceedings u/s 132 of the Act is initiated and at thesame time it drags out the authorisation of imposition of penalty u/s 270A and 271(1)(c) of the Act asextraterritorial. 10. Keeping aforesaid in mind, we find that, the appellant's contention that, the aforestated

Deputy Commissioner of Income Tax, Central Circle - 1, Mangalore vs. L Javerchand Jewellers Private Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 1542/BANG/2024[2019-20]Status: DisposedITAT Bangalore09 Jan 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20 L. Javerchand Jewellers Pvt. Ltd. No.1, 2Nd Floor & 3Rd Floor, Choksi Chamber Dcit 1Stagyari Lane Vs. Central Circle-1 Zaveri Bazar Mangaluru Mumbai 400 002

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Sri V. Parithivel, D.R
Section 132(4)Section 143(1)Section 143(3)Section 153CSection 250Section 270ASection 274

detailed reasons mentioned above. Accordingly the case of assessee clearly fall under the purview of “Misreporting” and accordingly the assessee is liable for penalty u/s. 270A of the Income Tax Act 1961. 8.4 In view of the discussion as above, and also considering the facts and circumstances of the case ... Subject to the above penalty proceedings under section 270A of the act, is disposed. Accordingly, I have no hesitation in levying penalty u/s. 270A(1) and Rs. 1,79,27,172 (200% of undisclosed tax of Rs. 89,63,586) is hereby levied as penalty for misreporting of income

Malcolm Darayes Pestonji, Vasai, Mumbai vs. DCIT, Central Circle-2, Thane, Mumbai

In the result, appeal of the assessee is allowed

ITA 3431/MUM/2024[2018-19]Status: DisposedITAT Mumbai03 Jan 2025AY 2018-19

Bench: Smt. Beena Pillai & Shri Prabhash Shankar

For Appellant: Shri Bhupendra ShahFor Respondent: Shri R. R. Makwana (Sr. DR)
Section 133ASection 143Section 143(3)Section 270ASection 274

income processed u/s 143[1]. 2. In the facts and circumstances of the case and in law, the CIT[A] erred in levying penalty u/s 270A on the basis of notice wherein no specific charge of either filing of underreporting or misreporting of income was mentioned and thereby passing ... that the ld.CIT(A) has usurped the jurisdiction of the AO in issuing a fresh show cause notice and went on to impose penalty u/s 270A of the Act, without realizing that parallel penalty proceeding was still not concluded by the AO as no penalty order was either passed

Anil Kumar Paik, Kolkata vs. DCIT, Cir.; 8(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 494/KOL/2024[2018-19]Status: DisposedITAT Kolkata02 Jan 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.492 To 494/Kol/2024 Assessment Years: 2013-14 & 2018-19 Anil Kumar Paik……………………………..……………………………...……Appellant C/O S.N. Ghosh & Associates, Advocates 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kol-1. [Pan: Aflpp6567R] Vs. Dcit, Circle-8(1), Kolkata…………....….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Sailen Samadder, Addl. Cit – Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 01, 2025 Date Of Pronouncing The Order : January 02, 2025 Order Per Bench: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That The Appeals Have Been Pending For Considerable Period & No One Has Appeared On Behalf Of The Assessee But Simply Filed An Application By Which The Assessee Sought An Adjournment Of The Case For Today. On Perusal Of Records, We Find That Multiple Dates Of Hearing Were Scheduled But The Assessee Failed To

Section 250Section 250(6)Section 270ASection 68

No.493/Kol/2024. Since, we have remanded back the main appeal in ITA No.493/Kol/2024 to the file of the Assessing Officer, therefore, consequential penalty u/s 270A of the Act has no legs to stand and the same has become infructuous. Accordingly, is dismissed as infructuous. However, the penalty proceedings would be resurrected

Anil Kumar Paik, Kolkata vs. DCIT, Cir. 8(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 493/KOL/2024[2018-19]Status: DisposedITAT Kolkata02 Jan 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.492 To 494/Kol/2024 Assessment Years: 2013-14 & 2018-19 Anil Kumar Paik……………………………..……………………………...……Appellant C/O S.N. Ghosh & Associates, Advocates 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kol-1. [Pan: Aflpp6567R] Vs. Dcit, Circle-8(1), Kolkata…………....….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Sailen Samadder, Addl. Cit – Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 01, 2025 Date Of Pronouncing The Order : January 02, 2025 Order Per Bench: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That The Appeals Have Been Pending For Considerable Period & No One Has Appeared On Behalf Of The Assessee But Simply Filed An Application By Which The Assessee Sought An Adjournment Of The Case For Today. On Perusal Of Records, We Find That Multiple Dates Of Hearing Were Scheduled But The Assessee Failed To

Section 250Section 250(6)Section 270ASection 68

No.493/Kol/2024. Since, we have remanded back the main appeal in ITA No.493/Kol/2024 to the file of the Assessing Officer, therefore, consequential penalty u/s 270A of the Act has no legs to stand and the same has become infructuous. Accordingly, is dismissed as infructuous. However, the penalty proceedings would be resurrected

Anil Kumar Paik, Kolkata vs. DCIT, Cir. 8(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 492/KOL/2024[2013-14]Status: DisposedITAT Kolkata02 Jan 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.492 To 494/Kol/2024 Assessment Years: 2013-14 & 2018-19 Anil Kumar Paik……………………………..……………………………...……Appellant C/O S.N. Ghosh & Associates, Advocates 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kol-1. [Pan: Aflpp6567R] Vs. Dcit, Circle-8(1), Kolkata…………....….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Sailen Samadder, Addl. Cit – Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 01, 2025 Date Of Pronouncing The Order : January 02, 2025 Order Per Bench: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find That The Appeals Have Been Pending For Considerable Period & No One Has Appeared On Behalf Of The Assessee But Simply Filed An Application By Which The Assessee Sought An Adjournment Of The Case For Today. On Perusal Of Records, We Find That Multiple Dates Of Hearing Were Scheduled But The Assessee Failed To

Section 250Section 250(6)Section 270ASection 68

No.493/Kol/2024. Since, we have remanded back the main appeal in ITA No.493/Kol/2024 to the file of the Assessing Officer, therefore, consequential penalty u/s 270A of the Act has no legs to stand and the same has become infructuous. Accordingly, is dismissed as infructuous. However, the penalty proceedings would be resurrected

Deputy Commissioner of Income Tax, (Exemptions), Circle-1, Bengaluru vs. Rashtrotthana Parishat, Bengaluru

In the result, the appeal filed by the Revenue is allowed

ITA 1666/BANG/2024[2017-18]Status: HeardITAT Bangalore30 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

For Appellant: Ms. Neera Malhotra CIT-D.RFor Respondent: Sri Prakash Shridhar Hegde, CA
Section 11Section 11(6)Section 250Section 270ASection 274

r.w.s. 270A of the Act dated 23/12/2019 requesting the assessee trust to appear and show cause as to why an order imposing a penalty u/s 270A of the Act should not be made under section 270A of the Act. The AO in the said penalty notice had also observe that ... held that the claim of depreciation made by the assessee in his return was inadvertent and a bonafide mistake and accordingly deleted the penalty u/s 270A of the Act. 6. Aggrieved by the order of the ld. CIT(A)/NFAC dated 04.07.2024, the Revenue has filed the present appeal before

Sumo Logic, Inc., Usa vs. The Assistant Commissioner of Income Tax, International Taxation, Circle 3(1)(2), Delhi

In the result, appeal of the assessee is partly allowed as indicated above

ITA 3350/DEL/2023[2021-22]Status: DisposedITAT Delhi27 Dec 2024AY 2021-22

Bench: Shri Saktijit Dey & Shri S. Rifaur Rahman(Assessment Year : 2021-22 Sumo Logic, Inc. Vs. Acit, Circle Int. Tax 3(1)(2), 3Rd Floor, 305 Main Street, Delhi. Redwood City, California, Foreign, United States. C/O Deloitte Haskins & Sells Llp, Tower-B, 7Th Floor, Building 10, Dlf Cyber City Complex, Phase-Ii, Gurgaon-122002. (Pan: Abecs 9368 P) (Appellant) (Respondent) Assessee By : Shri Sachit Jolly, Adv. & Shri Aditya Rathore, Adv. Revenue By : Shri Vijay B Vasanta, Cit Dr Date Of Hearing : 03.10.2024 Date Of Order : 27.12.2024 O R D E R Per S. Rifaur Rahman, Am : 1. The Captioned Appeal Preferred By The Assessee Is Directed Against The Assessment Order Dated 28.09.2023 Passed By The Learned Assistant Commissioner

For Appellant: Shri Sachit Jolly, Adv. &For Respondent: Shri Vijay B Vasanta, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)

issued, applicable interest to be charged and credit of taxes, if any after verification from the ITD system are to be allowed. Penalty u/s 270A is being proposed to initiate as discussed in earlier paragraphs of the order. Detailed computation of tax payable and interest charged u/s 234A, 234B ... Assessing Officer to verify the same and allow after verification as per law. 16. With regard to ground no. 10 on initiation of penalty u/s 270A of the Act, since it is premature ground, accordingly dismissed. 17. In the result, appeal of the assessee is partly allowed as indicated above