2021 (8) TMI 452

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....g total income of Rs. 1307,37,84,038/-. Thereafter, assessee filed revised return of income with increased claim of TDS on 05.03.2009. Thereafter, the assessment was framed u/s. 143(3) r.w.s. 144C of the Act and the total income was determined at Rs. 4585,87,70,541/- by making various additions/disallowances amounting to Rs. 3355,12,31,399/-. Aggrieved by the final assessment order, Assessee filed appeal before ITAT. ITAT vide order dated 13.06.2014 deleted additions/disallowances to the extent of Rs. 3279.25 crores, additions/disallowances to the extent of Rs. 68.60 crores were set aside to the file of AO for reconsidering the matter in light of the directions in the order and confirmed the additions/disallowances to the extent of Rs. 4.86....

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....iv) which was not tenable as per law and the same was upheld by the Hon'ble IT AT in the preceding years as well as the year under consideration? 4. Whether on the facts & the circumstances of the case, Ld. CIT(A) was correct in deleting the penalty of Rs. 12,000/- on disallowance of insurance charges of Rs. 33,852/- paid on the time of acquisition of vehicles? 5. Whether on the facts & the circumstances of the case, Ld. CIT(A) was correct in deleting the penalty of Rs. 49,000/- on disallowance of expenditure incurred on motor bikes given to various contestants at TV shows, amounting to Rs. 1.43 lacs u/s. 40(a)(ia) which was not tenable as per law and the same was upheld by the Hon'ble IT AT in the year under consideration & the....

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....to penalty levied by AO u/s. 271(1)(c) of the Act and which was deleted by CIT(A). Before us, Learned DR supported the order of AO. 6. Learned AR on the other hand reiterated the submissions made before the lower authorities. He thereafter pointed to the summary chart placed in the paper book. From the summary chart he pointed that the various additions/disallowances were made by AO and these were also sustained by the Tribunal. Against the order of Tribunal whereby the additions have been upheld by Tribunal, assessee has challenged the order of Tribunal before the Hon'ble Delhi High Court and the Hon'ble Delhi High Court in ITA No. 668/2014 order dated 19.11.2015 has admitted the appeal of the assessee by holding that substantial ....