2021 (1) TMI 632

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....02.2017 passed by the Commissioner of Income Tax (Appeals) -4, Mumbai [hereinafter referred to as the "CIT(A)"] relevant to the A.Ys.2006-07. 3. The assessee has raised the following grounds: - "1. The order passed by the learned Commissioner of Income Tax (Appeals) u/s. 271(1)(c) is bad in law. 2. The learned Commissioner of Income Tax (Appeals) erred in confirming penalty of Rs. 14,10,000/-u/s. 271(l)(c) of the Income Tax Act, 1961. 3. The learned Commissioner of Income Tax (Appeals) failed to appreciate that penalty u/s. 271(0(c) had been initiated initiated by the predecessor Assessing Officer in the case of same assessee for the same assessment year on additions made in respect of the same issues and the p....

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....urn of income on 29.03.2008 declaring total income to the tune of Rs. 3,34,36,493/- under the normal provisions of I. T. Act and declared book profit u/s 115JB of the Act of Rs. 98,57,631/- Based on the direction of DRP, the final order u/s 143(3) r.w.s. 144C(13) was passed on 18.08.2010 assessing total income of Rs. 4,80,19,930/- under the normal provisions of I. T. Act and book profit u/s 115JB of the I. T. Act of Rs. 1,97,48,820/- by making the following addition read as under.:- Normal Provisions of I. T. Act (i) TP adjustments Rs. 1,24,73,795/- (ii) Cash expenses Rs. 26,45,716/- (iii) Disallowance u/s 14A of the I. T. Act Rs. 11,85,990/- Book Profit u/s 115JB of I. T. Act (i) Disallowance u/s 14A ....