Revenue's Penalty Appeals Dismissed for AY 2012-13 & 2013-14 The Tribunal dismissed the Revenue's appeals against penalty deletion u/s 271(1)(c) for the Assessment Years 2012-13 and 2013-14, citing the deletion of ...
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Revenue's Penalty Appeals Dismissed for AY 2012-13 & 2013-14
The Tribunal dismissed the Revenue's appeals against penalty deletion u/s 271(1)(c) for the Assessment Years 2012-13 and 2013-14, citing the deletion of quantum additions by the Tribunal as the basis for nullifying the penalty.
Issues Involved: The judgment involves appeals filed by the Revenue against penalty deletion u/s 271(1)(c) of the Income Tax Act, 1961 for the Assessment Years 2012-13 and 2013-14.
Issue 1: Penalty Deletion u/s 271(1)(c) - Assessment Year 2012-13 and 2013-14
The Revenue challenged penalty deletion by the ld. CIT(A) under section 271(1)(c) of the Act. The AO imposed a penalty based on unexplained investment in land. However, during the proceedings, the Tribunal deleted the quantum additions made by the AO. The ld. CIT(A) considered the Tribunal's decision in quantum proceedings and deleted the penalty. The Tribunal noted that once the quantum additions were deleted, the penalty had no basis to stand on. The ld. DR did not contest the factual aspect, leading to the dismissal of the Revenue's appeals as they became infructuous.
Conclusion: The Tribunal dismissed the Revenue's appeals against penalty deletion u/s 271(1)(c) for the Assessment Years 2012-13 and 2013-14, citing the deletion of quantum additions by the Tribunal as the basis for nullifying the penalty.
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