9911796707
TMI Blog2025 (3) TMI 464X X X X Extracts X X X X X X X X Extracts X X X X ..... me-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2006-07. 2. The grounds of appeal raised by the Assessee are as follows:- 1. The learned CIT(A) has erred in law and on facts of the case in confirming initiation of penalty proceedings u/s 271(1)(c) of the Act. 2. The learned CIT(A) has erred in law and on facts of the case in confirming levy of penalty of Rs. 12,00,659/- u/s 271(1)(c) of the Act in respect of addition of Rs. 35,67,018/- made by the learned Assessing Officer. 3. Both the lower authorities have passed the orders without properly appreciating the facts and they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from ti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessing Officer, the assessee has taken up the issue with Ld. First Appellate Authority who restricted the addition to Rs. 35,67,018/-. The Assessing Officer subsequently levied the impugned penalty u/s 271(1)(c) of the Act on the addition of Rs. 35,67,018/- made on the basis of loos paper found during search. 5. Aggrieved, the assessee preferred appeal before the Ld. CIT(A) who confirmed the impugned penalty on the ground that the assessee has furnished inaccurate particulars of income and the Assessing Officer has made addition on the basis of analysis of data & incriminating document found during the course of search action. 6. Aggrieved by the order of the Ld. CIT(A) confirming the penalty, the assessee is now in appeal before ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... penalty order wherein it is mentioned that 'as brought out in the assessment order, it is very clear that the assessee has furnished inaccurate particulars of income to the tune of Rs. 39,31,296/- and therefore this is a fit case for levy of penalty u/s 271(1)(c)'. To conclude, the Assessing Officer levied penalty holding that 'the assessee has committed default u/s 271(1)(c) of the Act by way of furnishing inaccurate particulars of income and committed default within the meaning of Section 271(1)(c) of the Income-tax Act, 1961'. On this issue, we straight away find that the Assessing Officer vide penalty order dated 20.07.2021 u/s 271(1)(c) of the Act imposed penalty on additions made alleging 'furnishing of inaccurate particulars of inco ..... X X X X Extracts X X X X X X X X Extracts X X X X
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