9911796707
TMI Blog2022 (11) TMI 1016X X X X Extracts X X X X X X X X Extracts X X X X ..... s only settled the matter under VSVS 2020 insofar as the issues that are raised in the appeal filed as against the assessment u/s 143(3) of the I.T.Act. the assessee has not settled the penalty imposed u/s 271D under VSVS 2020. CIT(A) has erred in rejecting the appeal of the assessee stating that the issue raised in the appeal has become infructuous and the same has been dismissed as infructuous. The issue is restored to the files of the CIT(A). The CIT(A) is directed to adjudicate the grounds raised before him as regards the merits of imposition of penalty u/s 271D of the I.T.Act. Appeal filed by the assessee is partly allowed for statistical purposes - ITA No.572/Bang/2022 - - - Dated:- 21-9-2022 - Shri George George K, JM And Ms.Padm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment order dated 30.12.2020 and the same has been accepted by the designated authority. It was submitted that the assessee is not liable to the imposed with penalty u/s 271D of the I.T.Act. However, the A.O. rejected the contentions of the assessee and imposed penalty of Rs.50 lakh u/s 271D of the I.T.Act for violating the provisions of section 269SS of the I.T.Act. 4. Aggrieved by the order imposing penalty u/s 271D of the I.T.Act, the assessee preferred an appeal before the first appellate authority. The CIT(A) dismissed the appeal of the assessee as withdrawn and infructuous, since, according to the CIT(A), the assessee had settled the matter under VSVS 2020. 5. Aggrieved by the order of the CIT(A), the assessee has filed the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not adjudicating all the grounds of appeal raised by the Appellant as reproduced in para No. 16 of the statement of facts filed before this Hon'ble Tribunal on the facts and circumstances of the case. 5. Without prejudice the learned Commissioner of Income Tax [Appeals] failed to adjudicate the condonation of delay application filed by the appellant on the facts and circumstances of the case. 6. Without Prejudice to the other grounds above, the Appellant denies himself liable to the penalty levied by the learned assessing officer under Section 271D of the Act amounting to Rs.50,00,000/- under the facts and circumstances of the case. 7. The Appellant craves leave of this Hon'ble Income Tax Appellate Tribunal to add, al ..... X X X X Extracts X X X X X X X X Extracts X X X X
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