BISHWANATH PRASAD,MUZAFFARPUR vs. AC/DCIT CENTRAL CIRCLE, MUZAFFARPUR
In the result, all the appeals of the both the assessee in ITA
ITA 161/PAT/2023[2015-16]Status: HeardITAT Patna29 Aug 2024AY 2015-16
Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am
For Appellant: Shri SK Tulsiyan, &For Respondent: Shri Ashwani Kr. Singal, DR
Section 132Section 132(4)Section 133ASection 148Section 271(1)(c)Section 44A
B). The said deeming provisions are not applicable to the orders passed by the Commissioner (Appeals) and the Commissioner. [Para 63]
The imposition of penalty is not automatic, i.e., imposition of penalty even if the tax liability is admitted, is not automatic. Even if the assessee has not challenged the order of assessment levying tax and interest and has paid
