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TMI Blog2020 (8) TMI 557X X X X Extracts X X X X X X X X Extracts X X X X ..... RDER PER SUCHITRA KAMBLE, JM This appeal is filed by the assessee against the order dated 14/1/2019 passed by CIT(A)- 28, New Delhi for Assessment Year 2015-16. 2. The grounds of appeal are as under:- " 1. The Ld. CIT(A) has wrongly concluded that the appellate willfully and deliberately concealed its income. The conclusion is incorrect both on facts and in law and hence the penalty u/s 271(1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sition which amounted to Rs. 14,84,895/- but inadvertently in the return Rs. 85,05,595/- was claimed as interest. However, the Assessing Officer was not convinced with the explanation of assessee on the ground that the assessee company was not carrying on any business activity during the year as well as in earlier years, therefore, expenses claimed by it cannot be allowed. Therefore, the Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... td. alongwith other decisions of different Courts, concluded that the assessee has furnished inaccurate particulars of income leading to the concealment of income to the extent of Rs. 86,94,165/- and imposed the penalty of Rs. 26,86,497/-, being 100% of the tax sought to be evaded on the above income and passed the order. 4. Being aggrieved by the penalty order, the assessee filed appeal before t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was claimed as interest. However, the Assessing Officer was not convinced with the explanation of assessee merely on the ground that the assessee company was not carrying on any business activity during the year as well as in earlier years, therefore, expenses claimed by it cannot be allowed. Therefore, the Assessing Officer disallowed the total expenses amounting to Rs. 86,94,165/- and added back ..... X X X X Extracts X X X X X X X X Extracts X X X X
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