SHRI PRITPAL SINGH,DEHRADUN vs. THE ASSISTANT COMMISSIONER OF INCOME TAX , CIRCLE-2, DEHRADUN
In the result, the appeal of the Assessee is allowed
ITA 189/DDN/2019[2014-2015]Status: DisposedITAT Dehradun15 Sept 2023AY 2014-2015
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
For Appellant: Shri Savyasachi Kumar Sahai, AdvFor Respondent: Shri Amar Singh Rana, Sr. DR
Section 271(1)(c)Section 50CSection 56(2)(vii)
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
