2021 (1) TMI 281

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..... s. HELD THAT:- As brought to our notice that the quantum additions made by the AO stands deleted by the order of the tribunal dated 10.11.2020 and hence, the penalty does not survive. The facts have not been disputed by the Ld. DR. Since all the quantum additions stands deleted, we hereby hold that the penalty levied u/s 271(1)(c) do not survive at this juncture. - ITA No. 6416/Del/2015 (A .....

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..... ) of the I.T. Act, 1961 to ₹ 1,35,900/- as against penalty of ₹ 3,86,00,000/- imposed by the AO on the ground that some of the additions made were of debatable nature ignoring the fact that the assessee had not provided any evidence in support of its explanation. 3. On the facts and circumstances of the case and in law, Ld. CIT(A) has erred in reducing the penalty u/s 271(1)(c) o .....

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..... facts and circumstances of the case and in law, Ld. CIT(A) has erred in reducing the penalty u/s 271(1)(c) of the I.T. Act, 1961 to ₹ 1,35,900/- as against penalty of ₹ 3,86,00,000/- imposed by the AO ignoring the ratio of decision of the Hon'ble Supreme Court in the case of MAK Data Pvt. Ltd. vs. CIT (2013) 358 ITR 593 (SC) wherein it has been held that even voluntary disclosure .....

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