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“appeal before CIT(A)”

AppealsSection 246ASection 246A1,827 judgments

The decision most relied on for appeal before CIT(A) is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on appeal before CIT(A)

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

CIT v. Premkumar Arjundas Luthra (HUF)
297 CTR 614 · 2017 · High Court
659
citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT
199 ITR 351 · 1993 · High Court
441
citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

New Diwan Oil Mills v. CIT
296 ITR 495 · 2008 · High Court
351
citing judgments

The High Court can return a reference unanswered if the assessee fails to appear or provide assistance. This illustrates the broader principle that appellate authorities have inherent power to dismiss appeals for non-prosecution when a party does not effectively pursue their case.

Judgments citing appeal before CIT(A)

Titan Company Limited 9Earstwhile Known As Titan Industries Limited), Krishnagiri vs. ACIT Ltu 1, Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 506/CHNY/2018[2011-12]Status: DisposedITAT Chennai29 May 2024AY 2011-12

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri T. Surya Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

allowable expenditure under the Act and hence, he disallowed the entire claim of assessee claimed at Rs.4,80,99,369/-. Aggrieved, assessee preferred appeal before CIT(A). 3.2 The CIT(A) after considering the submissions of the assessee confirmed the disallowance holding that the assessee could not prove that ... thereby the AO disallowed total expenses relatable to exempt income u/s.14A r.w.rule 8D(2) at Rs.22,53,976/-. Aggrieved, assessee preferred appeal before CIT(A). The CIT(A) confirmed the action of the AO and dismissed the ground of assessee’s appeal. Aggrieved, now assessee is in appeal before

Titan Company Limited 9Earstwhile Known As Titan Industries Limited), Krishnagiri vs. ACIT Ltu 1, Chennai

In the result, the appeals filed by the assessee in ITA Nos

ITA 505/CHNY/2018[2010-11]Status: DisposedITAT Chennai29 May 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

For Appellant: Shri T. Surya Narayana, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 143(3)

allowable expenditure under the Act and hence, he disallowed the entire claim of assessee claimed at Rs.4,80,99,369/-. Aggrieved, assessee preferred appeal before CIT(A). 3.2 The CIT(A) after considering the submissions of the assessee confirmed the disallowance holding that the assessee could not prove that ... thereby the AO disallowed total expenses relatable to exempt income u/s.14A r.w.rule 8D(2) at Rs.22,53,976/-. Aggrieved, assessee preferred appeal before CIT(A). The CIT(A) confirmed the action of the AO and dismissed the ground of assessee’s appeal. Aggrieved, now assessee is in appeal before

Bharat Harshadrai Booch, Mumbai vs. ITO Ward 33(1)(2), Mumbai

ITA 82/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 May 2024AY 2014-15

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Kinjal BhutaFor Respondent: Shri Ashok Kumar Ambastha
Section 143(3)Section 263Section 44ASection 68

Appellant under Section 143(3) read with Section 263 of the Act on 23/12/2019. Being aggrieved, the Appellant preferred 2 appeal before CIT(A). By way of notice dated 15/01/2021, the hearing of appeal was fixed on 22/01/2021. However, the same could not be attended by the Appellant. In response ... without considering the submissions filed by the Appellant, we set aside the order, dated 06/11/2023, passed by the CIT(A) and restore the appeal before CIT(A) at its original number for denovo adjudication as per law after granting the Appellant reasonable opportunity of being heard. Thus, Ground

Shree Bankey Bihari Educational Society, Ghaziabad vs. ADIT, CPC, Bengaluru

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

ITA 925/DEL/2024[2022-2023]Status: DisposedITAT Delhi29 May 2024AY 2022-2023

Bench: Ld. CIT(A) and filed detailed submissions before him the same is reproduced below:

For Appellant: 1) That the appellant has e filed its ITR of the AY 2022-23 on 24.12.2022
Section 11Section 12A(1)(ac)Section 143(1)Section 2(15)Section 80G(5)(i)

month from the due date for filing return of income u/s 139(1) of the Act. 3. That the Appellant Society had filed appeal before CIT(A) against the aforesaid Intimation. The Appeal was decided by Addl./JCIT (A)-3, Hyderabad vide his order dated 12.02.2024 wherein by wrongly referring

Takenaka India Pvt Ltd, Gurgaon vs. JCIT (OSD) Circle-25(1), Gurgaon

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

ITA 5581/DEL/2019[2012-13]Status: DisposedITAT Delhi29 May 2024AY 2012-13

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2012-13] M/S. Takenaka India Pvt.Ltd., Vs Cit (A)-44, First Floor, Tower-C, Vatika First New Delhi. India Place, Mehrauli Gurgaon Road, Gurgaon, Haryana-122002. Pan-Aadct6143P Appellant Respondent Appellant By Shri Ashutosh Mohan Rastogi & Shri Dhruv Seth, Adv. Respondent By Shri Gaurav Bansal, Sr. Dr Date Of Hearing 15.04.2024 Date Of Pronouncement 29.05.2024 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By Commissioner Of Income Tax (Appeals) (“Cit(A)”)-44, New Delhi Dated 24.04.2019 For The Assessment Year 2012-13. 2. The Assessee Has Assailed The Correctness Of The Order On Following Grounds:-

Section 143(2)Section 143(3)Section 250(6)Section 271(1)(c)Section 92CSection 92C(3)Section 92D

reasons mentioned in TP order rejected the CUP method and applied the TNMM as the Most Appropriate Method. The Assessee preferred an appeal before CIT(A) which was decided in favour of the Revenue. Hence, the Assessee has filed an appeal before Hon'ble ITAT against the above orders

Anjali Saini, Zirakpur vs. ITO-Ward-5(5), Chandigarh

The appeal of the assesse is allowed for statistical purposes

ITA 620/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh28 May 2024AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: NoneFor Respondent: Smt. Amanpreet Kaur, Sr. DR
Section 142(1)Section 147Section 148Section 250(6)Section 253Section 271Section 271(1)(b)

order and penalty order during the recovery proceedings and the assessee received the papers through the authorities. 20.2 That the assessee filed the appeal before CIT(A) on 18.02.2022, during the course of the first appellate proceedings u/s. 250, IT Act, the notice

Mahavir Kelavani Mandal, Antroli vs. Ward- Exemption, Vadodara

In the result, the appeal of the assessee is allowed

ITA 468/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad27 May 2024AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2016-17 Mahavir Kelavani Mandal, Vs Deputy Commissioner Of Antroli, Income-Tax, C/O. Mahavir Kelavani Mandal, Bangalore Nadiad, Gujarat – 387366 Pan: Aactm 6322 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sunil Talati, Ar Revenue By : Shri N.J. Vyas, Sr Dr सुनवाई की तारीख/Date Of Hearing : 14/05/2024 घोषणा की तारीख /Date Of Pronouncement : 27/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokar: Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016-17 Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-4, Bengaluru (Hereinafter Referred To As 'Cit(A)’) Dated 29.02.2024, In The Matter Of Intimation Issued U/S 143(1) Issued By Cpc, Bangalore On 01.03.2019. 2. Following Are The Grounds Of Appeal Before Us:_ “1. The Ld. Cit(A) Has Erred In Upholding The Disallowance Made In The Intimation Order Passed U/S 143(1) Of The It Act Which Was Passed Without Giving Any Opportunity Of Being Heard To Your Appellant. In The Said Intimation Order, The Claim Of Exemption U/S 11 Of The It Act Is Denied & A Demand Is Raised. Such Arbitrary Disallowance Of Exemption Is Prayed To Be Deleted. 2. The Ld. Cit(A) Has Upheld The Disallowance Of Exemption U/S 11 Of The It Act In The Intimation Order Passed U/S 143(1) Of The It Act Making An Addition Of Rs. 40,67,000/- On Account Of Income Chargeable U/S 12(2) Of The Mahavir Kelavani Mandal Vs. Dcit Asst. Year : 2016-17 2

For Appellant: Shri Sunil Talati, ARFor Respondent: Shri N.J. Vyas, Sr DR
Section 11Section 12(2)Section 12ASection 139(9)Section 143(1)Section 250

rejected the request stating the reason that the rectification rights are transferred to the jurisdictional AO. The assessee also filed an appeal before CIT(A) against such addition. 7. The CIT(A) while passing order u/s 250 of the Act concluded that the assessee had not filed return of income

Income Tax Officer, Mumbai vs. S P International, Mumbai

Accordingly, we do not find any infirmity in the order passed by the CIT(A). All the grounds raised by the Revenue are dismissed as being without merit

ITA 430/MUM/2024[2012-13]Status: DisposedITAT Mumbai27 May 2024AY 2012-13

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 147Section 69C

Being aggrieved by the assessment order, dated 19/12/2019, passed under Section 143(3) read with Section 147 of the Act, the Assessee preferred appeal before CIT(A) challenging the validity of the reassessment proceedings as well the addition of INR 3,19,29,587/- made by the Assessing Officer ... were undertaken through banking channel. Further, while recording the submissions of the Assessee in relation to Ground No. 2 and 3 raised in appeal before CIT(A) (starting from page 10 of 32 of the order impugned), the CIT(A) has listed the documents which were furnished by the Assessee

Pga Constructions Pvt. Ltd, Mumbai vs. ITO, Ward 15(2)(4), Mumbai

ITA 390/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 May 2024AY 2017-18

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri H.M. Bhatt
Section 143(3)Section 68

Section 68 of the Act to the ‘Nil’ income returned by the Appellant. 4. Being aggrieved, the Appellant challenged the aforesaid addition in appeal before CIT(A). Vide order, dated 29/11/2023, the CIT(A) dismissed the appeal observing that the Appellant had failed to furnish documents in support ... CIT(A) and restore the issue back to the file of CIT(A) with the directions to 3 adjudicate the grounds raised in appeal before CIT(A) afresh as per law after granting the Appellant a reasonable opportunity of being heard. In terms of the aforesaid, Ground

Vinco Sales and Services Pvt Ltd, Mumbai vs. Asst. Commissioner of Income Tax 13(3)(2), Mumbai

In the result, appeals filed by the assessee are allowed for statistical purpose

ITA 4582/MUM/2023[2015-2016]Status: DisposedITAT Mumbai27 May 2024AY 2015-2016

Bench: Shri. Narender Kumar Choudhry & Smt. Renu Jauhriassessment Year: 2016-17 Assessment Year: 2015-16

Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(iii)Section 37(1)

Aggrieved with the order, the assessee filed appeal before CIT(A)/NFAC. Vide order dated 23.06.2023, the Ld. CIT(A) deleted the addition made u/s. 14A r.w. rule 8D of Rs. 34,20,703/- and observed that the ground & ITA NO. 4581/MUM/2023 (A.Y: 2016-17) Vinco Sales and Services

Vinco Sales and Services Pvt Ltd, Mumbai vs. ACIT-13(3)(2), Mumbai

In the result, appeals filed by the assessee are allowed for statistical purpose

ITA 4581/MUM/2023[2016-2017]Status: DisposedITAT Mumbai27 May 2024AY 2016-2017

Bench: Shri. Narender Kumar Choudhry & Smt. Renu Jauhriassessment Year: 2016-17 Assessment Year: 2015-16

Section 143(3)Section 14ASection 250Section 36(1)Section 36(1)(iii)Section 37(1)

Aggrieved with the order, the assessee filed appeal before CIT(A)/NFAC. Vide order dated 23.06.2023, the Ld. CIT(A) deleted the addition made u/s. 14A r.w. rule 8D of Rs. 34,20,703/- and observed that the ground & ITA NO. 4581/MUM/2023 (A.Y: 2016-17) Vinco Sales and Services

M/S Varun Resources Limited, Mumbai vs. Commissioner of Income Tax (Appeal)-Circle 5(3)(1), Mumbai

In the result, the appeal is partially allowed

ITA 4518/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 May 2024AY 2017-18

Bench: the NCLT during the course of assessment proceedings. Notice was issued to the liquidator Mr. Sanjeev Maheshwari but for no avail. It was learnt that assessee under reported income as Rs 34,06,89,638/- as per order dated 3

Section 115JSection 143(2)Section 143(3)Section 147Section 270Section 270ASection 270A(2)Section 274Section 69A

payable on under reported income was imposed u/s. 270A of the Act. Assessee went in appeal before CIT(A), who dismissed assessee’s appeal as not maintainable and having become infructuous due to the pendency of liquidation process. This led the Assessee/through liquidator to approach this Tribunal. 3. The appellant/assessee ... filed this appeal on the following grounds: “GROUND 1 A. On the facts and circumstances of the case, Commissioner of Income Tax Appeals (the CIT Appeals) erred in levying the penalty of Rs. 6,05,32,030/- being 50% of the tax payable on underreported income. B. The learned CIT

Sanjeev Kumar Goyal, Fatehabad vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assesse is allowed

ITA 80/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 143(2)Section 250(6)Section 253Section 68

also not meet the conditions of recording in accounts and offering satisfactory explanation with regards to nature & source thereof. viii) The assessee filed appeal before CIT(A). According to the Id. CIT(A) vide his order dated 26.10.2021 passed in appeal No. 10853/2018-19/IT/CIT(A)-5/Ldh/2021-22, the settled position

The South India Club, New Delhi vs. ITO Ward Exemption 2(3), New Delhi

In the result, the appeal filed by the Assessee is partly

ITA 354/DEL/2024[2018-19]Status: DisposedITAT Delhi22 May 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 11Section 12ASection 143(1)Section 143(1)(a)

u/s.143(3) r.w.s.143(3A) and 143(3B) on 08.02.2021, wherein the Assessing Officer has denied the exemption claimed u/s.11 and we have filed appeal before CIT(A), NFAC and the same is pending. XIII. For the reasons stated above, the CIT(A) may be pleased to hold that the appellant

Late Shri Balkrishan Joshi (Through Legal Heir Shri Bhoopendra Joshi), Indore vs. The Income Tax Officer-5(1), Indore

Appeal is allowed partly

ITA 402/IND/2023[2008-09]Status: DisposedITAT Indore21 May 2024AY 2008-09

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2008-09 Late Shri Balkrishan Joshi Income-Tax Officer, (Through L/H Shri 5(1), Bhoopendra Joshi), Indore बनाम/ 541, Alok Nagar, Vs. Kanadia Road, Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Abjpj 0180 C Assessee By Shri S.N. Agrawal & Shri Bavesh Agrawal, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 16.05.2024 Date Of Pronouncement 21.05.2024

Section 143(3)Section 253(5)

scrutiny and the AO passed assessment- order computing long-term capital gain at Rs. 60,59,070/-. Aggrieved, the assessee went in first-appeal before CIT(A) but did not get success. The assessee filed next appeal being ITA No. 608/Ind/2013 to ITAT, Indore which was decided by ITAT vide ... /254 assessing the long-term capital gain at Rs. 54,17,700/-. Still aggrieved by this consequential order, the assessee again filed first-appeal to CIT(A). The CIT(A) decided assessee’s appeal vide order dated 19.06.2023 granting part-relief. Now, the assessee has come in next appeal impugning

Ravi Shishodia (L/H of Nannu), Ghaziabad vs. ITO Ward - 2(5), Ghaziabad

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

ITA 372/DEL/2020[2010-11]Status: DisposedITAT Delhi21 May 2024AY 2010-11

Bench: SHRI G. S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

Section 144Section 147Section 148Section 46ASection 54BSection 54F

Ravi Shishodia vs. ITO 5. Aggrieved by the order of the Assessing Officer, the appellant assessee preferred appeal before CIT(A) with the grounds that the assessment order was without complying with the mandatory conditions u/s 147 to 151 as envisaged under the Income Tax. The Income Tax Officer erred

Pearls Creative Adsolutions Pvt. Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

The appeal is dismissed in limine

ITA 3767/DEL/2018[2012-13]Status: DisposedITAT Delhi21 May 2024AY 2012-13

Bench: Sh. Pradip Kumar Kedia & Sh. Sudhir Kumarassessment Year: 2012-13 Pearls Creative Adsolutions Vs. Dcit Pvt. Ltd., 705, 7Th Floor, Circle – 19 (2) Manjusha Building, Nehru New Delhi Place, New Delhi-110019 Pan No.Aafcp0010M (Appellant) (Respondent) Appellant By None Respondent By Sh. Vivek Vardhan, Sr. Dr Date Of Hearing: 09/05/2024 Date Of Pronouncement: 21/05/2024 Order Per Sudhir Kumar, Jm:

Section 143Section 144

dated 27.03.2015 assessed the total income of Rs.7,57,67,590/-. 3. Aggrieved by the order passed by AO, the assessee filed the appeal before CIT(A) but the Ld. CIT(A) dismissed the appeal ex- parte against which this appeal has been filed before us. 4. We have heard

M/S. Vydehi Super Speciality Hospital Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bengaluru

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 559/BANG/2024[2018-19]Status: DisposedITAT Bangalore17 May 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Shri V. Parithivel, D.R

circumstances the appellant's case. 4. At the outset, it is observed that there was a delay of 27 days in filing the appeal before CIT(A) in assessment year 2017-18. He has not condoned the delay and dismissed the appeal in limine. In assessment year

M/S. Vydehi Super Speciality Hospital Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bengaluru

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 558/BANG/2024[2017-18]Status: DisposedITAT Bangalore17 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Shri V. Parithivel, D.R

circumstances the appellant's case. 4. At the outset, it is observed that there was a delay of 27 days in filing the appeal before CIT(A) in assessment year 2017-18. He has not condoned the delay and dismissed the appeal in limine. In assessment year

Model Sales Agency Pvt Ltd, Mumbai vs. Income Tax Officer, 5(2)(3), Mumbai

In the result, in terms of paragraph 9 above, the appeal preferred

ITA 388/MUM/2024[2012-13]Status: DisposedITAT Mumbai17 May 2024AY 2012-13

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Tanzil R. Padvekar
Section 271(1)(c)Section 274Section 3

sought to be evaded on the addition of INR 36,00,000/-, was levied by the Assessing Officer. Being aggrieved, the Appellant preferred appeal before CIT(A) 4. against the levy of above penalty. Vide order, dated 29/11/2023, the CIT(A) dismissed the appeal for want of explanation and documentary