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“levy of penalty”

PenaltySection 271Section 2715,057 judgments

The decision most relied on for levy of penalty is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on levy of penalty

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

CIT v. Manu Engg
122 ITR 306 · 1980 · High Court
505
citing judgments

When levying a penalty under Section 271(1)(c), the Assessing Officer must clearly specify whether it is for concealment of income or furnishing inaccurate particulars. An ambiguous notice or order using "and/or" for these limbs, or a standard proforma without striking irrelevant clauses, indicates non-application of mind and renders the penalty unsustainable.

Hindustan Steel Ltd. v. State of Orissa
83 ITR 26 · 1972 · Supreme Court
502
citing judgments

An order imposing penalty for failure to carry out a statutory obligation results from quasi-criminal proceedings. Penalty is not ordinarily imposed unless the party acted deliberately in defiance of law, was guilty of contumacious or dishonest conduct, or acted in conscious disregard of their obligation.

Judgments citing levy of penalty

General Electric International Inc., Gurgaon vs. DCIT, International Taxation Circle 2(3)(2), Mumbai

ITA 3498/MUM/2023[2016-17]Status: DisposedITAT Mumbai16 May 2024AY 2016-17

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Veerbhandra Mahajan
Section 142(1)Section 143(3)Section 144C(3)Section 250Section 271(1)(c)

case and in law, the Ld. CIT(A) erred in confirming the action of the Learned Assessing Officer ('Ld. AO') in levying a penalty of INR 30,57,730 under section 271(1)(c) of the Act. 4. On the facts and in the circumstances of the case ... confirmed the levy of penalty u/s 271(1)(c) on account of concealment of income, without appreciating the fact as under- a) The Ld. AO has levied penalty u/s 271(1)(c) of the Act on account on furnishing of inaccurate particulars of income. b) The Appellant has provided bona

M/S. World Trade Impex Ltd., Baroda vs. The Additional Commissioner of Income Tax, Circle-5, Baroda

In the result, the appeal of the assessee is hereby allowed

ITA 1580/AHD/2016[2003-04]Status: DisposedITAT Ahmedabad15 May 2024AY 2003-04

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

For Appellant: Shri MK Patel, ARFor Respondent: Shri SudhankarVerma, Sr. D.R
Section 41(1)

639/Ahd/2012 appeal by the assessee 36. The only issue raised by the assessee is that the learned CIT(A) erred in confirming the levy of penalty under section 271(1)(c) of the Act for Rs. 49,52,688/- only. 37. The facts in brief are that the assessee ... made. The finding in the assessment order may be sufficient to make addition to total income but the same cannot be basis for levy of penalty. Accordingly, the assessee prayed to drop the penalty proceedings. 37.3 However, the AO found that the assessee neither during the assessment proceedings nor during

World Trade Impex Ltd., Baroda vs. The ACIT., Circle-4, Baroda

In the result, the appeal of the assessee is hereby allowed

ITA 639/AHD/2012[2003-04]Status: DisposedITAT Ahmedabad15 May 2024AY 2003-04

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

For Appellant: Shri MK Patel, ARFor Respondent: Shri SudhankarVerma, Sr. D.R
Section 41(1)

639/Ahd/2012 appeal by the assessee 36. The only issue raised by the assessee is that the learned CIT(A) erred in confirming the levy of penalty under section 271(1)(c) of the Act for Rs. 49,52,688/- only. 37. The facts in brief are that the assessee ... made. The finding in the assessment order may be sufficient to make addition to total income but the same cannot be basis for levy of penalty. Accordingly, the assessee prayed to drop the penalty proceedings. 37.3 However, the AO found that the assessee neither during the assessment proceedings nor during

ITO, WD.9(1), Kolkata vs. M/S Maharaj Vincom Pvt. Ltd., Kolkata

ITA 35/KOL/2021[2009-10]Status: DisposedITAT Kolkata15 May 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.35/Kol/2021 Assessment Year: 2009-10 Ito, Ward-9(1), Kolkata……………….......................…...……………....Appellant Vs. M/S Maharaj Vincom Pvt. Ltd……............…..........................…..…..... Respondent 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] C.O. No.6/Kol/2023 (A/O I.T.A. No.35/Kol/2021) Assessment Year: 2009-10 M/S Maharaj Vincom Pvt. Ltd……............…..........................…....... Cross-Objector 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] Vs Ito, Ward-9(1), Kolkata …………..….......................…...……………....Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Department. Date Of Concluding The Hearing : March 07, 2024 Date Of Pronouncing The Order : May 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: This Appeal By The Revenue & Corresponding Cross-Objection By The Assessee Have Been Preferred Against The Order Dated 08.09.2020 Of The Commissioner Of Income Tax (Appeals)-7, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 143(1)Section 143(3)Section 147Section 250Section 263

Dhiraj Suri vs ACIT 98 lTD 87 (Del). In the said case, appeal was filed by the assessee before the Tribunal against the levy of penalty. In the appeal challenging the penalty order, the assessee challenged the validity of block assessment order which had determined the tax liability ... therefore it is open to the assessee to set up the question of validity of the assessment in the appeal against the levy of penalty. 8.9. We also derive support from another judgement of Hon'ble Bombay High Court in the case of Inventors Industrial Corporation

Striver Capital Advisors Private Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Circle 14(3)(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 4503/MUM/2023[2015-16]Status: DisposedITAT Mumbai15 May 2024AY 2015-16

Bench: Shri B.R. Baskaran () & Shri Vikas Awasthy ()

Section 271Section 271(1)(c)Section 274

Income Tax Act, 1961 (herein after referred to as ‘the Act’). 2. The assessee in appeal has inter alia assailed levy of penalty on the ground of defective notice issued under section 274 read with section 271(1)(c) of the Act. 2 I.T.A. No. 4503/Mum/2023 Striver Capital Advisors

Amrik Singh (Through His Lr), Ghaziabad vs. ITO, Ward 1(5), Ghaziabad

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

ITA 1751/DEL/2023[2014-15]Status: DisposedITAT Delhi15 May 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Mr. Sankalp Malik, AdvFor Respondent: Shri Kanv Bali, Sr. DR
Section 148ASection 271(1)(c)Section 271D

Assessing Officer, Addl. CIT, Range-1, Ghaziabad. 2. Let us take up the ITA No. 1750/Del/2023 for AY 2014-15 challenging the levy of penalty u/s 271D of the Act. ITA No. 1750 & 1751/Del/2023 Smt Kamalpreet Singh 3. At the outset, we find that there is delay in filing

Amrik Singh (Through His Lr), Ghaziabad vs. ITO, Ward 1(5), Ghaziabad

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

ITA 1750/DEL/2023[2014-15]Status: DisposedITAT Delhi15 May 2024AY 2014-15

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

For Appellant: Mr. Sankalp Malik, AdvFor Respondent: Shri Kanv Bali, Sr. DR
Section 148ASection 271(1)(c)Section 271D

Assessing Officer, Addl. CIT, Range-1, Ghaziabad. 2. Let us take up the ITA No. 1750/Del/2023 for AY 2014-15 challenging the levy of penalty u/s 271D of the Act. ITA No. 1750 & 1751/Del/2023 Smt Kamalpreet Singh 3. At the outset, we find that there is delay in filing

Dilipkumar Vitthaldas Desai, Vadodara vs. The Income Tax Officer, Ward-3(1)(1), Vadodara

ITA 84/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad14 May 2024AY 2012-13

Bench: The Tribunal Has Caused The Delay Of 87 Days In Filing The Appeal. The Assessee Enclosed The United States Passport Copy Of His Brother, Who Visited India In December 2023. We Are Satisfied With The Reasons Stated In The Notarized Affidavit Thereby We Hereby Condone The Delay Of 87 Days In Filing The Above Appeals & Adjudicate The Cases On Merits.

Section 139Section 142(1)Section 144Section 148Section 160Section 163Section 271(1)(c)Section 9

with law. Thus the appeal filed by the Assessee in ITA No. 83/Ahd/2024 is allowed for statistical purpose. 8. ITA No. 84/Ahd/2024 is levy of penalty u/s. 271(1)(c) of the Act. Since the quantum appeal is set aside to the file of Jurisdictional Assessing Officer, the Penalty order

Dilipkumar Vitthaldas Desai, Vadodara vs. The Income Tax Officer, Ward-3(1)(1), Vadodara

ITA 83/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad14 May 2024AY 2012-13

Bench: The Tribunal Has Caused The Delay Of 87 Days In Filing The Appeal. The Assessee Enclosed The United States Passport Copy Of His Brother, Who Visited India In December 2023. We Are Satisfied With The Reasons Stated In The Notarized Affidavit Thereby We Hereby Condone The Delay Of 87 Days In Filing The Above Appeals & Adjudicate The Cases On Merits.

Section 139Section 142(1)Section 144Section 148Section 160Section 163Section 271(1)(c)Section 9

with law. Thus the appeal filed by the Assessee in ITA No. 83/Ahd/2024 is allowed for statistical purpose. 8. ITA No. 84/Ahd/2024 is levy of penalty u/s. 271(1)(c) of the Act. Since the quantum appeal is set aside to the file of Jurisdictional Assessing Officer, the Penalty order

Ganpat Manikrao Sorgikar, Pune vs. National Faceless Appeal Centre (NFAC) Delhi and Local Jurisdiction Assessing Officer Ward 9(4), Delhi

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

ITA 199/PUN/2024[2012-2013]Status: DisposedITAT Pune14 May 2024AY 2012-2013

Bench: Shri S.S.Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.199/Pun/2024 (E-Appeal) "नधा"रण वष" Assessment Year : 2012-13 Ganpat Manikrao Sorgikar, Vs. Nfac, Delhi/ Plot No.3B, Flat No.97, Assessing Officer, Sat Angan Appt, Cdc, Ward-9(4),Delhi Chikhali Road, Chinchwad, Pune 411 019 Maharashtra Pan : Cijps2716L Appellant Respondent

For Respondent: Smt. Deepa Sanjay Hiray
Section 143(1)Section 143(3)Section 148Section 271(1)(c)

into the reasons for the delay, simply condoned the delay by passing one line cryptic order. Moreover, the CIT(A) merely confirmed the levy of penalty u/s.271(1)(c) of the Act without referring to the factual situation and the law governing the facts of the case and also without ... relied upon by the assessee are inapplicable to the facts of the present case. Thus, the CIT(A)/NFAC had merely confirmed the levy of penalty by passing a cryptic and unreasoned order which cannot be sustained in the eyes of law. Therefore, the order of CIT(A)/NFAC

Bhavika Gunwant Patel, Nagpur vs. Income Tax Officer, Ward 4(3), Nagpur

In the result, appeal filed by the assessee are allowed

ITA 366/NAG/2023[2012-13]Status: DisposedITAT Nagpur14 May 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Abhay R. Marathe
Section 10(38)Section 143(3)Section 271(1)(c)Section 69C

That the penalty levied by the AO and confirmed by learned CIT(A) is illegal in as much as the ground for levy of penalty in penalty order is not in line with the ground for initiation of penalty in assessment order. The action of both the authorities is beyond ... proceedings, the assessee submitted that the addition was made on estimate basis and, therefore, no penalty can be levied. However, the Assessing Officer levied the penalty of ` 33,255, under section 271(1)(c) of the Act which was confirmed by the learned CIT(A) as well. The learned

Anand Shaktikumar Sancheti, Nagpur vs. Income Tax Officer, Ward 1(3), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 340/NAG/2023[2017-18]Status: DisposedITAT Nagpur14 May 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mukesh AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 115BSection 139(5)Section 142(1)Section 143(2)Section 270A

facts and circumstances of the case and in law, the learned CIT Appeals, NFAC, Delhi has grossly erred in confirming levy of penalty u/s 270A of the I.T. Act, 1961 which is illegal, invalid and against the principles of natural justice. 2. On the facts and circumstances of the case ... assessment has been completed on Anand Shaktikumar Sancheti ITA no.340/Nag./2023 income as shown in the revised return. As such the levy of penalty is unjustified, illegal and deserves to be deleted. 3. The Appellant craves leave to add, amend, alter, vary and / or withdraw any or all the above

Freyr Software Private Limited, Hyderabad vs. ACIT, Circle 8(1), Hyderabad

In the result, appeal of the assessee is allowed

ITA 90/HYD/2024[2020-21]Status: HeardITAT Hyderabad14 May 2024AY 2020-21

Bench: Shri Manjunatha G. & Shri K.Narasimha Chary

For Appellant: Shri R. Mohan Kumar, ARFor Respondent: Ms. Sheetal Sarin, DR
Section 10ASection 115JSection 143(3)Section 270ASection 270A(8)Section 270A(9)

section 270A(9) of the Act is admitted, no other view could be taken. On similar lines, learned CIT(A) also confirmed the levy of penalty. Hence this appeal. 5. Learned AR submitted that for levy of penalty under section 270A(8) of the Act, as a pre-condition, Revenue

Chemtex Global Engineers Private Limited, Mumbai vs. ACIT, Cir-15(1)(2), Mumbai

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

ITA 4626/MUM/2023[2011-12]Status: DisposedITAT Mumbai14 May 2024AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 250Section 271(1)(c)

appeal : “1. On the facts and in the circumstances of the case and in law the learned CIT (A) erred in confirming the levy of penalty u/s 271(1)(c) amounting to Rs. 1,94,330/- by the assessing officer on the addition made ... confirmed by the NFAC order dated 27/10/2023. 3 I.T.A. No.4626/Mum/2023 Chemtex Global Engineers Private Limited 5. The Ld. AR has submitted that the levy of penalty related to partial disallowance of expenses incurred for renewal of software license which were claimed as revenue expenses but treated as capital in nature

K J Somaiya and Sons Private Limited, Mumbai vs. ACIT Circle 2(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4241/MUM/2023[2015-16]Status: DisposedITAT Mumbai14 May 2024AY 2015-16

Bench: Shri B.R. Baskaran & Ms.Kavitha Rajagopalassessment Year :2015-16 K J Somaiya & Sons Private Limited, 45-47, Somaiya Bhavan, M.G Road, Fort, Mumbai – 400 001 Pan: Aaack-1894-K ---- Appellant Vs. Acit -2(2)(1),Mumbai Aaykar Bhavan, M.K. Road, Mumbai – 400 020. --- Respondent

For Appellant: Shri Vipul JoshiFor Respondent: Shri P.D.Chougule, Sr.DR
Section 143(3)Section 148Section 271(1)(c)

AnantharamVeerasinghaiah& Co. v. C.I.T., Andhra Pradesh, 1980 Supp SCC 13]”. Hence the addition made in the assessment order would not automatically lead to levy of penalty. In the instant case, the AO has initiated penalty proceedings for “concealment of particulars of income”. We have noticed that the assessee has furnished

M/S Happy Steel Private Ltd., Ludhiana vs. DCIT CC-2, Ludhiana

In the result, the appeal of the Assessee is allowed

ITA 397/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh13 May 2024AY 2016-17

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 397/Chd/2023 "नधा"रण वष" / Assessment Year : 2016-17 M/S Happy Steels Private Limited, Vs. The Dcit, बनाम B-Xxix, 2254, Central Circle-2, Kanganwal Road, Ludhiana P.O. Jugiana, Ludhiana 141120 "थायी लेखा सं./Pan No: Aaach6019D अपीलाथ" ./ Appellant ""यथ" / Respondent

For Appellant: Sh. Ashwani Kumar &For Respondent: Smt. Amanpreet Kaur, Sr.DR
Section 132Section 250(6)Section 271Section 271(1)(c)

Appeals)-5, Ludhiana is against law and facts on the file in, as much as he was not justified to arbitrarily uphold the levy of penalty u/s 271(1)(c) at Rs. 3,80,242/- 2. That levy of penalty and upholding the same ... separate and distinct proceedings. An issue may call for an addition during the assessment proceedings but it does not necessarily call for levy of penalty u/s Section 271 (1) (c) of the Act on the addition. Before levying penalty, it is to be established that the Assessee willfully concealed

Palghat Fine Arts Society, Palakkad vs. JCIT Palakkad Range, Palakkad

In the result, the appeals are allowed

ITA 109/COCH/2023[2012-13]Status: DisposedITAT Cochin10 May 2024AY 2012-13

Bench: Shri Sanjay Arora, Am & Ms.Kavitha Rajagopal, Jm

For Appellant: Ms.Rajalakshmy M, CAFor Respondent: Smt.J.M.Jamuna Devi, Sr.DR
Section 269SSection 269TSection 271DSection 271E

Assessee, directed against the Orders dated 15.02.2021 passed by the Commissioner of Income-tax (Appeals), Income Tax Department (‘CIT(A)’), confirming the levy of penalty under sections 271D and 271E of the Income-tax Act, 1961 (the Act), for assessment year (AY) 2012-2013, vide, again, separate orders of even ... counter such cash transactions. In view of the above facts, the A.O. was rightly satisfied that this was a fit case for levy of penalty u/s.271D. The A.O’s action is therefore upheld and the appellant’s appeal is accordingly dismissed.’ ‘6. Decision The order u/s.271E and submissions

Vardhman Automobiles (P) Ltd., Gurgaon vs. ITO, Gurgaon

ITA 3994/DEL/2015[2011-12]Status: DisposedITAT Delhi10 May 2024AY 2011-12

Bench: Shri Saktijit Dey, Hon’Ble Vice- & Shri M. Balaganesh

Section 271(1)(c)Section 271C

some typographical errors have crept in. The following words appearing in 3rd and 4th line of paragraph 9 “……there is no merit in levy of penalty under section 271(1)(c) of the Act and the same is deleted.”, should be read as “…….there is no merit in levy

Lanco Rithwik Joint Venture, Hyderabad vs. ITO, Ward-14(1), Hyderabad

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

ITA 232/HYD/2023[2018-19]Status: DisposedITAT Hyderabad09 May 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha, G. Hon’Ble Accounant Member Assessment Year: 2018-19 M/S. Lanco Rithwik Joint Vs. The Income Tax Officer, Ward – 14(1), Venture, Hyderabad. Plot No.37 & 39, Navodaya Colony, Road No.2, Banjara Hills, Hyderabad – 500034. Pan : Aabal3655J (Appellant / Assessee) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Aves Madhukar, Sr.A.R. Date Of Hearing: 09.05.2024 09.05.2024 Date Of Pronouncement:

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri AVES Madhukar, Sr.A.R
Section 142(1)Section 143(2)Section 143(3)Section 272ASection 272A(1)(d)

Appellate order of the CIT(A) dt. 07-02-2023 is erroneous, in as much as the Appellate Authority has upheld the levy of penalty u/s 272A(1)(d) by the AO, without fairly considering the reasons for delayed response to the notice ... ought to have appreciated that the Ld.AO erred in levying the penalty u/s 272A (1)(d) of the Act without appreciating the facts of the case and circumstances, leading to belated response to notice issued u/s 142(1) dt. 22- 12-2020 4. The Ld. CIT(A) ought to have

Usha Goyal, Delhi vs. DCIT, Circle-43(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3695/DEL/2023[2014-15]Status: DisposedITAT Delhi09 May 2024AY 2014-15

Bench: Shri Shamim Yahya & Shri Sudhir Pareekusha Goyal, Vs. Dcit, Circle 43 (1), 134/135, Vaishali, Pitampura, Delhi. Delhi – 110 034. (Pan : Aecpg5220J) (Appellant) (Respondent) Assessee By : None Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 07.05.2024 Date Of Order : 09.05.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)/National Faceless Appeal Centre (Nfac) Dated 26.06.2023 For The Assessment Year 2014-15. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “1. That On The Facts & In The Circumstances Of The Case, The Ld. Cit (A) Erred In Law & Facts In Confirming Penalty Imposed Of Rs.10,000/- U/S 271(1)(B) Of The Income Tax Act, 1961 Without Appreciating The Facts That There Was No Non- Compliance Of Notice Issued U/S 142(1) Of The Act Dated 06.11.2019 On The Scheduled Date 08.11.2019 As The Appellant Duly Filed Adjournment Before The Ld. Assessing Officer & Later On Filed All Requisite Details & Documents.

For Appellant: NoneFor Respondent: Shri Amit Katoch, Sr. DR
Section 139Section 142Section 142(1)Section 147Section 148Section 271(1)(b)Section 273BSection 274

notice issued under section 142(1) of the Income Tax Act, 1961 dated 06.11.2019 and alleged in the impugned order.” 4. Against this levy of penalty, assessee appealed before the ld. CIT(A) who confirmed the same. 5. Against this order, assessee has filed appeal before us. We have heard