2018 (12) TMI 1613

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....h. Gaurav Jain, Adv. For the Respondent : Sh. Kumar Hrishikesh, CIT DR ORDER PER BEENA A PILLAI, JUDICIAL MEMBER Present penalty appeals have been filed by assessee against order dated 30/06/2014 and 06/02/15 passed by Ld.CIT (A)-15, New Delhi for assessment year 2003-04 on following grounds of appeal: Grounds of ITA No. 4410/del/2014 AY 2003-04: 1. "That the CIT(A) e....

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.... on facts and in law in holding that appellant furnished inaccurate particulars of income by notionally booking profit after taking tariff rate of Rs. 5,92,per unit arbitrarily as against the prevailing market tariff of power charged by HSEB. 3.1 That the CIT(A) erred on facts and in law in not appreciating that no incorrect facts relating to the claim of deduction were disclosed by the a....

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....ons were made to total income. On disallowance of deduction under section 80-IA and section 80HHC of the Act, additions were upheld by Ld.CIT (A). Ld.AO accordingly, issued notice under section 274 of the Act, for levy of penalty under section 271(1)(c) of the Act. 3. Aggrieved by penalty order passed by Ld.AO, assessee preferred appeal before Ld.CIT(A), who upheld penalty on account of disallo....

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....0/10 passed by Hon'ble Delhi High Court in case of CIT vs Liquid Investment and Trading Co., in ITA No. 240/2009, and submitted that, admission of issue on which penalty has been levied would make it apparent that, such addition made is debatable. 8. On contrary, Ld. DR place reliance on orders of authorities below. 9. We have perused submissions advanced by both sides in light of records pl....