9911796707
TMI Blog2023 (6) TMI 666X X X X Extracts X X X X X X X X Extracts X X X X ..... ms of provision of Section 56(2)(vii) r.w. Section 45A of the Act and 50% of the interest received on compensation was offered for tax - AO treated revised return in response to Section 148 is invalid due to error in e-verification and no ITR-V (acknowledgement of ITR) was sent for verification - HELD THAT:- As the present appeal filed by the assessee in quantum proceedings is infructuous as both ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inst the order of the ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi ( CIT(A) in short) dated 09.02.2023 arising from the assessment order dated 14.09.2021 passed by the Assessing Officer (AO) under Section 144 r.w. Section 147 of the Income Tax Act, 1961 (the Act) concerning AY 2015-16. 2. The grounds of appeal raised by the assessee read as under: 1. Addition of Rs 9,13,100 was ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome at Nil where exempt income shown was Rs. 18,26,202/- being interest on land compensation from NOIDA Authority. The assessee thereafter filed revised return on 21.03.2017 again reporting Nil taxable income and claimed the entire interest on land compensation of Rs. 18,26,202/- as exempt. Thereafter, a notice under Section 148 dated 17.07.2019 was issued to assess the escapement of income on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in response to Section 148 is invalid due to error in e-verification etc. and added Rs. 9,13,101/- to the taxable income (as per original return of income) offered and assessed the income at Rs. 9,13,100/-. 4. In this factual backdrop, the ld. counsel submitted that he has no objection to the assessed income rather the assessee himself had offered the aforesaid income in the revised return rem ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the present appeal filed by the assessee in quantum proceedings is infructuous as both assessee and the Revenue are ad idem on taxability of the interest on income compensation from NOIDA Development Authority. Hence, mere initiation of penalty proceedings cannot be challenged unless some formal order on the point has been passed in accordance with law. The assessee may challenge the imposition o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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