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The Appellate Tribunal held that despite the addition u/s 69B of the Income Tax Act being justified, the penalty u/s 271(1)(c) cannot be levied due to ambiguity regarding the assessment year involved for the unaccounted cash payment made to the Tapadiya family members for the purchase of Baner land. The Tribunal emphasized that assessment and penalty proceedings are separate, allowing the assessee to make new pleas during penalty proceedings, even if the addition was sustained in quantum proceedings. Consequently, the Tribunal ruled in favor of the assessee, stating that the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre was not justified in sustaining the penalty levied by the Assessing Officer u/s 271(1)(c).
The Appellate Tribunal held that despite the addition u/s 69B of the Income Tax Act being justified, the penalty u/s 271(1)(c) cannot be levied due to ambiguity regarding the assessment year involved for the unaccounted cash payment made to the Tapadiya family members for the purchase of Baner land. The Tribunal emphasized that assessment and penalty proceedings are separate, allowing the assessee to make new pleas during penalty proceedings, even if the addition was sustained in quantum proceedings. Consequently, the Tribunal ruled in favor of the assessee, stating that the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre was not justified in sustaining the penalty levied by the Assessing Officer u/s 271(1)(c).
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