9911796707
TMI Blog2019 (11) TMI 1294X X X X Extracts X X X X X X X X Extracts X X X X ..... lty levied u/s. 271(1)(c) - Decided in favour of assessee. - ITA No. 2397/Ahd/2017 (Assessment Year 2011-12) - - - Dated:- 21-10-2019 - Shri Rajpal Yadav, Judicial Member And Shri Amarjit Singh, Accountant Member Revenue by: Shri Mudit Nagpal, Sr. D.R. Assessee by: Shri P.B. Parmar, A.R. ORDER PER : AMARJIT SINGH, ACCOUNTANT MEMBER:- This assessee s appeal for A.Y. 2011-12, arises from order of the CIT(A)-6, Ahmedabad dated 16-08-2017, in proceedings under section 271(1)(c) of the Income Tax Act, 1961; in short the Act . 2. The solitary ground of appeal of the assessee is filed against the decision of ld. CIT(A) in confirming ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etailed submission of the assessee is produced at page no. 2 to 4 of the penalty order passed u/s. 271(1)(c) of the Act. The assessing officer has not agreed with the explanation and stated that assessee has furnished inaccurate particulars of income and ld. CIT(A) has also dismissed the appeal of the assessee. Therefore, the assessing officer has levied penalty of ₹ 1,67,517/- at 100% of concealed income of ₹ 5,04,300/- on account of disallowance of various expenses as cited above in this order. 4. Aggrieved against the decision of assessing officer, the assessee has preferred appeal before the ld. CIT(A). The ld. CIT(A) has dismissed the appeal of the assessee. 5. We have heard the rival content ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the interest on delayed payment on account of rectification of the mistake and there was no concealment of particulars of income. Regarding disallowance of prior period consultancy services of ₹ 19,000/-, the assessee submitted that it has paid consultancy fees of ₹ 38000/- pertaining to F.Y. 2009-10 and F.Y. 2010-11 during the year under consideration after deduction of tax at source of ₹ 3800/-. The assessee explained that out of aforesaid payment an amount of ₹ 19000/- was pertained to F.Y. 2009-10 and its contention of applicability of provision of section 40(a)(ia) was rejected by the assessing officer. Regarding labour welfare expenses of ₹ 29,000/-, the assessee has explained that this amount was disal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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