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TMI Blog2025 (3) TMI 716X X X X Extracts X X X X X X X X Extracts X X X X ..... VDHESH KUMAR MISHRA, AM The appeal for the Assessment Year (hereinafter, the 'AY') 2016-17, filed by the assessee is directed against the order dated 19.07.2021 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi [hereinafter, the 'CIT(A)']. 2. The sole issue in dispute before us is in respect of levy of penalty of Rs. 10,000/- under section 271(1)(b) of the Income Tax Act, 1961 (her ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e on the record. It is evident from the record that the assessee, an Engineering Consultant, filed his Income Tax Return (hereinafter, the 'ITR') on 17.10.2016 declaring income of Rs. 2,98,79,750/-. The case was picked up for scrutiny. Consequentially, the assessment was completed at income of Rs. 3,40,73,552/-. During the course of assessment proceedings, the assessee did not ensure any complianc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r section 143(3) of the Act. 6. The Hon'ble Supreme Court, in the case of Hindustan steel Ltd. 83 ITR 26 has held that an order-imposing penalty for failure to carry out a statutory obligation is the result of a quasi-criminal proceedings and penalty will not ordinarily be imposed unless the party obliged either acted deliberately in defiance of law or was guilty of conduct contumacious or dishon ..... X X X X Extracts X X X X X X X X Extracts X X X X
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