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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

Lalabhagat Limbabhagat Sanya, Bhavnagar vs. The Income Tax Officer, Ward-1(4), Bhavnagar

Appeal of the assessee is partly allowed for statistical purposes

ITA 969/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad19 Jan 2024AY 2017-18

Bench: Ms. Suchitra R. Kambleassessment Year: 2017-18 Lalabhagat Limbabhagat Sanya, Vs Income Tax Officer, Plot No. 2541, City Ring Road, Ward-1(4), Opp. Talaja Jakatnaka, Bhavnagar, Bhavnagar Gujarat-364001 Pan : Ahups 1013 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Parimalsinh B. Parmar, Ar Revenue By : Shri Purushottam Kumar, Sr Dr सुनवाई की तारीख/Date Of Hearing : 10/01/2024 घोषणा की तारीख /Date Of Pronouncement : 19/01/2024

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri Purushottam Kumar, Sr DR
Section 142(1)Section 143(2)Section 144Section 234ASection 250Section 270ASection 271ASection 271FSection 272A(1)(d)Section 69A

erred in law and on facts of the case in confirming action of the ld. AO in levying penalty u/s 270A of the Act. 10. The ld. CIT(A) has erred in law and on facts of the case in confirming action of the Ld. AO in levying penalty u/s

Green Bio Tech, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

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

ITA 529/HYD/2023[2018-19]Status: DisposedITAT Hyderabad19 Jan 2024AY 2018-19

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumarआ.अपी.सं /Ita No. 529/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2018-19) Green Bio Tech Vs. Income Tax Officer Hyderabad Ward 15(1) Pan:Aaifg4254G Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate T. Chaitanya Kumar राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 18/01/2024 घोषणा की तारीख/Pronouncement: 18/01/2024 Order Per R.K. Panda, Vice-This Appeal Filed By The Assessee Is Directed Against The Ex-Parte Order Dated Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2018-19. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Ex-Parte Order Of The Learned Cit (A) Nfac In Confirming The Penalty Of Rs.22,78,444/- Levied By The Assessing Officer U/S 270A Of The Act.

For Appellant: Advocate T. Chaitanya KumarFor Respondent: : Smt. Sheetal Sarin, DR
Section 143(3)Section 270ASection 40A(3)

proceedings u/s 270A of the I.T. Act, 1961. Accordingly, notice was issued to the assessee asking it to explain as to why the penalty u/s 270A of the Act shall not be imposed. It was explained by the assessee that its targeted business area of operation is over Telangana, Andhra

Vdb Infra and Realty Private Limited, Bengaluru vs. Income-Tax Officer, Ward-7(1)(4), Bangalore

ITA 1017/BANG/2023[2017-18]Status: DisposedITAT Bangalore18 Jan 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojari

Section 250Section 270ASection 271ASection 44A

perused the materials available on record. The contention of the ld. A.R. is that the ld. AO has passed penalty order levying penalty u/s 270A(9)(a) of the Act stating that there is a mis-representation or suppression of the facts, thereby misreporting of income. However, in assessment order ... mentioned that levy of penalty u/s 270A(9)(c) of the Act. The ld. CIT(A) has confirmed the penalty u/s 270A(9)(a) of the Act, which was not the case of ld. AO. On the other hand, case of the ld. AO was the levy of penalty u/s

Deputy Commissioner of Income Tax, Circle-1(1), Raipur vs. Chhattisgarh State Power Transmission Company Ltd., Raipur

In the result, the appeal of the revenue in ITA No

ITA 3/RPR/2023[2017-18]Status: DisposedITAT Raipur14 Dec 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 2 & 3/Rpr/2023 Co Nos. 19 & 20/Rpr/2023 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri S.K Meena, CIT-DR
Section 115JSection 143(3)Section 270ASection 271(1)(c)Section 36(1)(va)

r.w.s. 270A of the Act dated 24.12.2019, wherein the assessee company was called upon to put forth an explanation as to why penalty u/s. 270A of the Act may not be imposed on it for underreporting/misreporting of income, Page 129 of APB. After the culmination of the assessment proceedings ... issued a “Show Cause Notice” (SCN) dated 16.10.2020 u/s. 274 r.w.s. 270A of the Act, wherein it was called upon to explain why penalty u/s. 270A of the Act may not be imposed on it for underreporting/misreporting income, Page 130 of APB. After that, the assessee company received

Deputy Commissioner of Income Tax, Circle-1(1), Raipur vs. Chhattisgarh State Power Transmission Company Ltd., Raipur

In the result, the appeal of the revenue in ITA No

ITA 2/RPR/2023[2016-17]Status: DisposedITAT Raipur14 Dec 2023AY 2016-17

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 2 & 3/Rpr/2023 Co Nos. 19 & 20/Rpr/2023 "नधा"रण वष" / Assessment Years : 2016-17 & 2017-18 The Deputy Commissioner Of Income Tax, Circle-1(1), Raipur (C.G.)

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri S.K Meena, CIT-DR
Section 115JSection 143(3)Section 270ASection 271(1)(c)Section 36(1)(va)

r.w.s. 270A of the Act dated 24.12.2019, wherein the assessee company was called upon to put forth an explanation as to why penalty u/s. 270A of the Act may not be imposed on it for underreporting/misreporting of income, Page 129 of APB. After the culmination of the assessment proceedings ... issued a “Show Cause Notice” (SCN) dated 16.10.2020 u/s. 274 r.w.s. 270A of the Act, wherein it was called upon to explain why penalty u/s. 270A of the Act may not be imposed on it for underreporting/misreporting income, Page 130 of APB. After that, the assessee company received

Scholars International Educational Foundation, Rishikesh vs. DCIT (E), Ghaziabad

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

ITA 2003/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Nov 2023AY 2017-18

Bench: Sh. Saktijit Deysh. M. Balaganesh

For Appellant: Ms. Monika Agarwal, AdvFor Respondent: Sh. Anuj Garg, Sr. DR
Section 11Section 11(6)Section 12ASection 270ASection 271(1)(c)Section 274

effective issue to be decided in this appeal is as to whether the ld. CIT(A) was justified in confirming the levy of penalty u/s 270A of the Income Tax Act, 1961 in the sum of Rs.72,99,406/- in the facts and circumstances of the instant case

South Eastern Coalfieds Limited, Bilaspur vs. Assistant Commissioner of Income Tax, Bilaspur

In the result, appeal of the assessee company is allowed for statistical purposes in terms of our aforesaid observations

ITA 314/RPR/2023[2017-18]Status: DisposedITAT Raipur30 Nov 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 314/Rpr/2023 "नधा"रण वष" / Assessment Year : 2017-18 M/S. South Eastern Coalfields Limited Seepat Road, Sarkanda, Bilaspur (C.G.)-495006 Pan: Aadcs2066E .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: S/shri Ajit Korde, Advocate &For Respondent: Shri Debashis Lahiri, CIT-DR
Section 246ASection 270ASection 270A(9)

NFAC erred in not adjudicating the ground of appeal challenging the validity of show cause-, notice issued by the Ld. AO before levying penalty u/s 270A. (a) That or. the facts and in the circumstances of the case and in law. the Ld. CIT(A), NFAC erred in not adjudicating ... order on the above issue. (d) Without prejudice to the above, the Ld. AO has erred in law and in facts, in levying penalty u/s 270A without establishing that the explanation furnished by the Appellant was not bona fide and Appellant did not disclose all material facts to substantiate explanation

Greenwoods Govt. Officers Welfare Society, Noida vs. DCIT Circle 52(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 609/DEL/2023[2018-19]Status: DisposedITAT Delhi26 Oct 2023AY 2018-19

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year: 2018-19

For Appellant: Shri S.D. Srivastava, AdvocateFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 142(1)Section 143(3)Section 270A

facts and circumstances of the present case, the order of the Ld. CIT(A) confirming the order of the Ld. AO imposing the penalty u/s 270A of the Income tax Act,1961 is erroneous both on facts and in law because of failure of Ld. AO to specify the specific

D C Polyester Limited, Mumbai vs. DCIT Central Circle-6(4), Mumbai

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

ITA 188/MUM/2023[2017-18]Status: DisposedITAT Mumbai17 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(1)Section 153ASection 24Section 270A

Chennai bench of Tribunal has held in the case of S Saroja (supra) that bonafide mistake committed while computing total income, the penalty u/s 270A of the Act should not be levied. 12. Accordingly, we are of the view that the impugned penalty levied u/s 270A

Jaypee Cement Corporation Limited, Noida vs. ACIT Circle 5(1)(1), Noida

In the result, the appeal of the assessee is allowed and stay application of the assessee is dismissed

ITA 1070/DEL/2023[2017-18]Status: DisposedITAT Delhi11 Sept 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshm/S. Jaypee Cement Vs. Acit, Corporation Ltd, Circle-5(1)(1), Sector-128, Gautam Noida Budh Nagar, Noida (Appellant) (Respondent) Pan: Aaacz2168D

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Mr. Waseem Arshad, CIT DR
Section 143(1)Section 270ASection 32A

issue to be decided in the instant appeal is as to whether the ld CIT(A) was justified in upholding the levy of penalty u/s 270A of the Act in the facts and circumstances of the instant case. 4. We have heard the rival submissions and perused the material available ... provided in section 270A(6)(a) of the Act, we hold that the present facts does not make the revenue eligible to levy penalty u/s 270A of the Act. 14. We find that the ld AR also made argument on the ground that there was absolutely no mala fide intention

Shri Chandraprabh Charitable Sanstha, Jaipur vs. ITO, Exemption Ward 1, Jaipur

In the result, appeal of the assessee in ITA No

ITA 364/JPR/2023[2019-20]Status: DisposedITAT Jaipur18 Aug 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 363 & 364/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2019-20 Shri Chandraprabh Charitable Sanstha, Shree Digamber Jain Mandir Campus, Durgapura, Jaipur cuke Vs. Income Tax Officer Exemption Ward-01, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAGTS 7441 B vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rajeev Sogani (C.A.), Shri Ruchika Sogani (Adv.) jk

For Appellant: Shri Rajeev Sogani (C.A.) &For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 11Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

facts and circumstances of the case and in law the ld. AO Shri Chandraprabh Charitable Sanstha vs. ITO has erred in imposing penalty u/s 270A without specifically pointing out whether the penalty was proposed on underreporting of income or underreporting is in consequence of any misreporting of income. The action

Shri Chandraprabh Charitable Sanstha, Jaipur vs. ITO, Exemption Ward 1, Jaipur

In the result, appeal of the assessee in ITA No

ITA 363/JPR/2023[2019-20]Status: DisposedITAT Jaipur18 Aug 2023AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 363 & 364/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2019-20 Shri Chandraprabh Charitable Sanstha, Shree Digamber Jain Mandir Campus, Durgapura, Jaipur cuke Vs. Income Tax Officer Exemption Ward-01, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAGTS 7441 B vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Rajeev Sogani (C.A.), Shri Ruchika Sogani (Adv.) jk

For Appellant: Shri Rajeev Sogani (C.A.) &For Respondent: Smt Monisha Choudhary (Addl. CIT) a
Section 11Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

facts and circumstances of the case and in law the ld. AO Shri Chandraprabh Charitable Sanstha vs. ITO has erred in imposing penalty u/s 270A without specifically pointing out whether the penalty was proposed on underreporting of income or underreporting is in consequence of any misreporting of income. The action

Deepak Kumar Rajoria, Ahmedabad vs. ITO, Ward-1(2), Bikaner

In the result, the appeal of the assessee is allowed

ITA 170/JODH/2022[2017-18]Status: DisposedITAT Jodhpur11 Aug 2023AY 2017-18

Bench: Assessing Authority Tax Was Paid & Adjust From Tds The Appellant Was Aware Of The Fact That There Is Any Form By Filing Which The Penalty May Be Dropped So The Penalty Was Never Leviable In This Case Therefore The Penalty U/S 270A May Please Be Cancelled. 3. The Appellant Prays For Justice & Relief. 4. The Appellant May Please Be Permitted To Raise Any Addition Or Alternative Ground At Or Before The Hearing.”

Section 143(3)Section 270ASection 271(1)(C)Section 274Section 80G

worthy CIT(A) has erred in confirming the penalty order imposed by the AO as it was not a fit case for levying penalty u/s 270A on account of misreporting of income hence the penalty imposed u/s 270A may please be quashed. Deepak Kumar Rajoria ... action of the AO in imposing 200 percent penalty on account of misreporting income because there was nothing in this case which attract penalty u/s 270A. That the appellant had already surrendered that wrong deduction claimed earlier before assessing authority Tax was paid and adjust from TDS the appellant

Jagson International Ltd., Delhi vs. DCIT Circle-13(1), Delhi

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

ITA 902/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

assessee is general in nature and does not require any specific adjudication. The ground No.6 raised by the assessee regarding the levy of penalty u/s 270A of the Act is premature for adjudication at this stage. Hence, dismissed. 14. The ground No.2 raised by the assessee is challenging the disallowance

JCIT Circle-13(1), New Delhi vs. Jagson International Ltd., New Delhi

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

ITA 1303/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Jagson International Ltd., Vs Dcit, H-35, 1St Floor, Circle-13(1), Jangpura Extension, Delhi. New Delhi – 110 014. Pan: Aaacj2147A Assessment Year: 2017-18 Dcit, Vs. Jagson International Ltd., H-35, 1St Floor, Circle-13(1), Delhi Jangpura Extension, New Delhi – 110 014. Pan: Aaacj2147A (Appellant) (Respondent) Assessee By : Shri Rajiv Saxena, Ms Sumangla Saxena & Shri Shyam Sunder, Advocates Revenue By : Mohd. Gayasuddin Ansari, Cit, Dr Date Of Hearing : 08.05.2023 Date Of Pronouncement : 04.08.2023

For Appellant: Shri Rajiv SaxenaFor Respondent: Mohd. Gayasuddin Ansari, CIT, DR
Section 115JSection 115VSection 143(3)Section 407

assessee is general in nature and does not require any specific adjudication. The ground No.6 raised by the assessee regarding the levy of penalty u/s 270A of the Act is premature for adjudication at this stage. Hence, dismissed. 14. The ground No.2 raised by the assessee is challenging the disallowance

Badaud Shri Vardhman Shiksha, Badaud vs. The ITO NFAC Delhi, New Delhi

Appeal is allowed

ITA 51/IND/2023[2018-19]Status: DisposedITAT Indore25 Jul 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2018-19 Badaud Shri Vardhaman Ito, बनाम/ Shiksha Samiti, Nfac, Badaud Delhi Vs. (Assessee / Appellant) (Revenue / Respondent) Pan: Aacab5370 Assessee By Shri Sharad Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.07.2023 Date Of Pronouncement 25.07.2023

Section 143(2)Section 143(3)Section 270ASection 270A(2)Section 270A(8)

also assessed the same at Rs. Nil, there is no variation in the Total Income of assessee. Ld. AR submitted that to attract penalty u/s 270A, there has to be any of the situations of under-reported income falling within clauses (a) to (g) of section 270A

Pratap Technocrats Private Limited, Jaipur vs. Principal Commissioner of Income Tax -1, Jaipur

In the result, appeal of the assessee is allowed

ITA 225/JPR/2023[2018-19]Status: DisposedITAT Jaipur18 Jul 2023AY 2018-19

Bench: The Date Of Hearing.”

For Appellant: Shri Rajeev Sogani (C.A.) &For Respondent: Shri Ajey Malik (CIT) a
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 80J

separate. It is explicitly confirmed by the fact that no penalty can be levied u/s 270A for addition u/s 143(1) while penalty u/s 270A can be levied for addition u/s 143(3). 4.2.vi The present case was selected for limited scrutiny and accordingly NFAC confined itself to the issues

Amar Nath, Gurugram vs. ITO, Ward 1(1), Gurgaon

ITA 74/DEL/2023[2017-18]Status: DisposedITAT Delhi10 Jul 2023AY 2017-18

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 133ASection 143Section 156Section 270Section 270ASection 270A(7)Section 270A(9)Section 69A

case of the appellant is not covered by the provisions of section 270AA of the Act as the AO has initiated the penalty u/s 270A(9) of the Act. Further it is found that the appellant suppressed the sale by Rs. 77,25,354/- from the regular books of accounts ... specified period and non-filing of appeal against assessment order are fulfilled, then the assessing officer shall grant immunity from imposition of penalty u/s 270A. Further sub-section (4) of 270AA of the Act provides that Assessing Officer shall within one month from the end of the month in which

Alrameez Construction Pvt Ltd, Mumbai vs. National Faceless Appeal Centre, Mumbai

In the result grounds of appeal raised by assessee is allowed

ITA 482/MUM/2023[2018-2019]Status: DisposedITAT Mumbai12 Jun 2023AY 2018-2019

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S Alrameez Construction Pvt. Ltd. 707/708, 7Th Floor, Jms Business Centre Behram Baug, Oshiwara Link Road, Jogeshwari West, Mumbai-400 080 Pan: Aafca8078A ...... Appellant Vs. Cit/Nfac Delhi ..... Respondent

For Appellant: NoneFor Respondent: Shri Manoj Kumar Sinha, Sr. AR
Section 143Section 148Section 250Section 270ASection 274Section 275Section 43C

already been disposed of by the Ld. CIT (A) against the assessee vide DIN No. ITBA/NFAC/APL-1/2022-23/1046156273. It is further noticed that order of penalty u/s 270A was finalized and imposed on 01.02.2022 i.e. without waiting for the outcome of quantum appeal pending, which is against the established practice between revenue ... ample time for this action is already there with AO u/s 275. 3. We have gone through the order of AO imposing penalty u/s 270A, order of Ld. CIT (A) and submissions of the assessee alongwith grounds of 4 M/s Alrameez Construction Pvt. Ltd. appeal taken. It is observed that

Orange Business Services India Solutions Private Limited (Formerly Known As Equant Solutions India Private Limited), Gurgaon vs. ACIT, Circle-3(1), Gurgaon

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

ITA 2026/DEL/2022[2018-19]Status: DisposedITAT Delhi30 May 2023AY 2018-19

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Us

For Appellant: Shri Rishabh Malhotra, ARFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 144BSection 144CSection 144C(13)Section 92B

Officer shall accordingly enhance income of the taxpayer by Rs. 52,15,13,144/-. The Assessing Officer may examine issue of initiation of penalty u/s 270A of the Act” Page 4 of 11 ITA No.-2026/Del/2022 Orange Business Services Indi 3. Against above order, the assessee has filed appeal