2019 (6) TMI 788

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... or DR ORDER PER KULDIP SINGH, JUDICIAL MEMBER : Appellant, M/s. Quality Enabled Remote Solutions (P) Ltd. (hereinafter referred to as 'the assessee') by filing the present appeal, sought to set aside the impugned order dated 15.11.2016 passed by Ld. Commissioner of Income-tax (Appeals)-30, New Delhi qua the Assessment Year 2005-06 confirming the penalty levied u/s 271(1)(c) of the Income-tax Ac .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... assessment order u/s 147 dated 20.03.2013 is also contrary to law and facts, void ab initio and not sustainable on various legal and factual grounds." 2. Briefly stated the facts necessary for adjudication of the controversy at hand are : On the basis of assessment completed under section 147 of the Act, penalty proceedings were initiated in this case on the ground that addition on account of und .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... Representatives of the parties to the appeal, gone through the documents relied upon and orders passed by the revenue authorities below in the light of the facts and circumstances of the case. 5. At the very outset, it is brought to our notice by the ld. AR for the assessee that addition made in the case u/s 68 of the Act has since been deleted by the Tribunal in assessee's own case in ITA No.92 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X