2019 (1) TMI 656

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.... the Respondent. P.C. : 1 The aforesaid appeals arise on common background and concern the same assessee, challenge the judgment of Income-Tax Appellate Tribunal ("the Tribunal" for short). The following questions have been presented for our consideration. (a) Whether on the facts and circumstances of the present case the Tribunal was justified in deleting the penalty of Rs. 4,473/levied under ....

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....he Department issued notice under Section 153C of the Income Tax Act ("the Act" for short) declaring total income of Rs. 60,74,594, Rs. 78,434,31/- and 8,51,910/- respectively. For the remaining two Assessment Years 2005-06 and 2006-07 which would also be within the purview of proceedings under Section 153C of the Act, the Assessee did not file the Returns of Income contending that for the said tw....

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....Counsel for the parties and having perused the documents on record, what emerges as an undisputed position is that the Assessee had filed returns of income for three assessment years even before the notice under Section 153C of the Act was issued. For remaining two years the Assessee contended that no such return was required to be filed since his income did not exceed the taxable limit. This late....