2019 (2) TMI 1367

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....anjay Goyal, CIT DR ORDER PER PRASHANT MAHARISHI, A. M. 1. This is an appeal filed by the revenue against the order of the ld CIT(A)- 1, New Delhi dated 31.10.2013 for the Assessment Year 2009-10. 2. The revenue has raised the following grounds of appeal:- "1. The order of the ld CIT(A) is not correct in law and facts. 2. On the facts and the circumstances of the case....

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....ct on 24.08.2010, after considering the reply of the assessee, the penalty was imposed vide order dated 28.03.2013 u/s 271E of the Act of Rs. 207954716/-. The assessee preferred an appeal before the ld CIT(A) who deleted the penalty vide order dated 31.10.2013 and therefore, the ld AO in appeal. 5. The ld DR supported the order of the ld AO. 6. The ld AR stated that the issue is squarely cov....

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....t case are the same as in earlier years and I find no reason to differ with the view taken by my predecessor. I have also gone through the order of Hon'ble Delhi High Court in the case of M/s Sahara India Mutual Benefit Company Limited (an associate concern) for AYs 1993-94, 1999- 00 & 2000-01. In the said order the Hon'ble Court, referring to its order dated 20.09.2012 in the appellant's own case....

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....CIT(A) in appellant's own case and Hon'ble High Court in a connected case are applicable on facts and in law to the present case and are binding. The two provisions u/s 269SS and 269T, and consequential penalties u/s 271D and 271E, are also pari materia. In the circumstances, I hold that appellant had reasonable cause as contemplated u/s 273B and was entitled to the exemption from levy of....