In the result, the appeal of the Assessee is allowed
Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) Shri Pritpal Singh, Vs. Acit, 71, Guru Road, Circle-2, Dehradun Dehradun (Appellant) (Respondent) Pan: Ahkps3632F Assessee By : Shri Savyasachi Kumar Sahai, Adv Revenue By: Shri Amar Singh Rana, Sr. Dr Date Of Hearing 22/08/2023 Date Of Pronouncement 15/09/2023
penalty u/s 271(1)(c) of the Act could be levied at an addition which has been made u/s 56(2)(vii)(b) of the Act on a deeming fiction. 3. We have heard the rival submission and perused the material available on record. The Assessee filed original return of income on 29.11.2014 for AY 2014-15 declaring total income