2019 (6) TMI 603

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....2. The brief facts of the case are that the assessee filed his return of income for the assessment year 2013-14 on 30.09.2013 admitting an income of Rs..21,69,180/-. This case was selected for scrutiny and notice under section 143(2) of the Act was issued on 02.09.2014 and served on the assessee. Subsequently, notice under section 142(1) issued on 11.08.2015, against which, the assessee furnished all details. After verification of the books of accounts, documents and information filed, the assessment was completed under section 143(3) of the Act on 03.03.2016 by assessing total income at Rs..28.28.870/- after making following additions: Loss on sale of Motor Cycle : Rs..3,040/- Disallowance u/s.40(a)(ia) : Rs..5,08,800/- Staff Welfar....

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....low. In this case, the assessment was completed under section 143(3) of the Act by assessing total income at Rs..28.28.870/- after making various additions. Moreover, while framing the assessment order, the Assessing Officer has not given any findings/observations that the assessee has contravened the provisions of section 269SS of the Act. Against the additions/disallowances, it is an admitted fact that the Assessing Officer proposed for initiating penalty proceedings under section 271(1)(c) of the Act. Thus, it is a clear cut case that on perusal of the assessment order, the Assessing Officer has not recorded any satisfaction recorded regarding penalty proceedings under section 271D of the Act. 6. On perusal of the appellate order, we fi....