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TMI Blog2019 (6) TMI 89X X X X Extracts X X X X X X X X Extracts X X X X ..... le deciding assessee s quantum appeal [ 2017 (4) TMI 1444 - ITAT MUMBAI] - HELD THAT:- Tribunal while deciding the quantum appeal of the assessee in the order referred to above restored all the issues to the AO for fresh adjudication. In the assessment order passed in pursuance to the directions of the Tribunal, the Assessing Officer has accepted some of the claim of the assessee and decided a co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e : Shri S.K. Jain ORDER PER SAKTIJIT DEY. J.M. The aforesaid appeal has been filed by the assessee challenging the order dated 11th December 2017, passed by the learned Commissioner (Appeals) 24, Mumbai, confirming penalty of ₹ 2,33,38,168, imposed under section 271(1)(c) of the Income Tax Act, 1961 (for short the Act ) for the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tmental Representative also agreed with the aforesaid submissions of the learned Authorised Representative. 5. We have considered rival submissions and perused the material on record. It is evident from the facts on record that in the original assessment order, the Assessing Officer made certain additions and also changed the head of income in respect of certain items of income whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resh assessment order, the Assessing Officer had not initiated any proceeding for imposition of penalty under section 271(1)(c) of the Act. Be that as it may, once the additions / disallowances on the basis of which penalty under section 271(1)(c) of the Act lost its existence due to the order passed by the Tribunal in quantum appeal filed by the assessee, penalty under section 271(1)(c) of the Ac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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