Bench: Shri Sudhanshu Srivastavaand\Nshri, Nikhil Choudhary\Nita No. 242/Lkw/2025\N Assessment Year: 2017-18\Nskyhigh Infrastructures Pvt\Nltd\Nv.\Ncp-2 Ii Floor, Gomti Plaza,\Nvikas Khand, Gomti Nagar,\Nlucknow-226010.\Nincome Tax Officer-6(1)\Npratyaksh Kar Bhawan,\Nlucknow-226001.\Npan:Aatcs1687B\N(Appellant)\N(Respondent)\Nappellant By:\Nshri P. K. Kapoor, Ca\Nrespondent By:\Nshri Amit Kumar, Dr\Ndate Of Hearing:\N10 06 2025\Ndate Of Pronouncement:\N31 07 2025\Norder\Nper Nikhil Choudhary.:\Nthis Is An Appeal Filed By The Assessee Against The Order Of\Nthe Learned Commissioner Income Tax (Appeals)/Nfac, Delhi\Nu/S 250 Of The Income Tax Act, 1961 (“Act”, For Short) Dated\N17.01.2025 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of\Nthe Assessee That Was Filed Against The Order Of The Assessing\Nofficer U/S 143(3) Of The Act On 28.12.2019. The Grounds Of\Nappeal Are As Under: -\N“1.

272A(1)(d) of the Act.\n9. BECAUSE on a due consideration of facts and circumstances of the case, the ld.\n"CIT(A)" ought to have directed the Assessing Officer to drop the penalty\nproceedings initiated under section 270A of the Act without recording proper\nsatisfaction.\n10. BECAUSE on a due consideration of facts and circumstances of the case