2014 (4) TMI 746

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....al ORDER Per R. C. Sharma (A. M.) : This is an appeal filed by the assessee against the order of CIT(A), dated 3-2-2012 for the assessment year 2007-08, in the matter of imposition of penalty under Section 271(1)(c) of the I.T. Act. Heard on condonation of delay 2. This appeal is barred by three days. Learned AR has filed an affidavit of Shri Ajay S Singhal, Director of M/s Plaza Ca....

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....For both the additions the AO levied penalty under Section 271(1)(c). 6. It was contended by the learned AR that assessee has provided PAN Number and address of the loan creditors to the AO. However, due to non-cooperation of the creditors their confirmation could not be filed. As per learned AR since the assessee has filed the PAN Number and the address of the loan creditors and it was incumbe....

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....rity and donation could not be made the reason for imposition of penalty under Section 271(1)(c) of the I.T. Act. 9. We have considered rival contentions, gone through the orders of the authorities below and found from the record that assessee has given loan to three persons as mentioned by AO at page 1 of his order. Even though assessee has filed the PAN Number, but the confirmation of the res....