2025 (1) TMI 97

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..... 2021-22, arises against the Commissioner of Income Tax (Appeals) [in short "CIT(A)"], Delhi's DIN and order no. ITBA/APL/M/250/2024- 25/1066193370(1), dated 28.06.2024 involving proceedings under section 271DA of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties at length. Case file perused. 3. Coming to the assessee's first and foremost legal ground that .....

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..... tation in very terms. 5. I have given my thoughtful consideration to the vehement rival submissions and see merit in the assessee's arguments. This is for the precise reason that although the department has indeed sought to get out of the rigor of the impugned limitation period, the factual position which goes unrebutted is that the impugned penalty order is very well passed beyond limitation. I .....

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