2018 (2) TMI 1924

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.... Tech Group of Educational Institutions and his family members, in which Smt. R. Mahalakshmi, the assessee, the daughter of Shri R. Rangarajan was also covered. Before the search and seizure operation, the assessee filed her return u/s. 139 admitting a total income of Rs. 33,91,800/- on 17.10.2008. The assessee has not admitted any undisclosed income u/s. 132(4). Post search and seizure enquiry, the Revenue got confirmation from the sellers of the plots that they received on money payments from the assessee, when the said facts were brought to the assessee, she had admitted the on-money receipts of Rs. 2,46,30,500/-. Subsequently, on issue of notice u/s. 153A, the assessee filed a return admitting the total income of Rs. 2,02,62,800/- on 29....

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....as busy in connection with the tax audit matters and hence he could not appear for the hearing. 4. The CIT(A) misinterpreted the order of the Hon'ble Income Tax Appellate Tribunal in ITA No. 986/2013 in assessee's own case and illogically confirmed the levy of penalty u/s. 271(1)(c). 5. The CIT(A) failed to appreciate that the Hon'ble Income Tax Appellate Tribunal has nowhere recorded that it is reinstating the penalty levied u/s. 271(1)(c) 6. The CIT(A) ought to have quashed the order of the Assessing Officer in reinstating the penalty proceedings u/s. 271(1)(c). 7. Any other ground that may be adduced at the time of hearing." 5. The AR inviting our attention to the ITAT order submitted that the assessee's appeal in ITA No. 9....