2023 (8) TMI 297 - SCH - Income Tax

Penalty u/s 271D - non comply with the provisions of Section 269SS - As decided by HC 2012 (9) TMI 845 - DELHI HIGH COURT ITAT was correct in law in holding that there was a reasonable cause due to which, assessee failed to comply with the provisions of Section 269SS and it was not correct to state that the Tribunal based its decision on the only ground that Section 269SS cannot be applied to the assessee whose business itself was the collection of deposits - As submitted by Revenue/Appellant(s) and Assessee/Respondent(s) that in these appeals the relied upon judgments were orders impugned in 2023 (7) TMI 1053 - SC ORDER and connected matters has dismissed those civil appeals. In the circumstances, appropriate orders may be made in these appeals also. HELD THAT - Having regard to the aforesaid submissions and having regard to the fact that C.A supra were dismissed by this Court these appeals also stand dismissed.

Summary

Issues involved:
The judgment involves the dismissal of multiple civil appeals based on the orders impugned in C.A. No.3883/2014 and C.A. No.3886/2014 and connected matters.

Dismissal of Civil Appeals:
The Supreme Court, with Hon'ble Mrs. Justice B.V. Nagarathna and Hon'ble Mr. Justice Ujjal Bhuyan presiding, heard the submissions from the learned Panel Advocate for the Revenue/Appellant(s) and Mr. Percy J. Pardiwala, Senior Counsel for the Assessee/Respondent(s). It was noted that the relied upon judgments were orders impugned in C.A. No.3883/2014 and C.A. No.3886/2014, which were previously dismissed by the Court on 18.07.2023. Consequently, the Court decided to dismiss the present appeals as well, in line with the previous orders.

Disposition of Pending Applications:
In light of the above, the Court ordered that the pending application(s), if any, shall stand disposed of along with the dismissal of the appeals.