2021 (10) TMI 663

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....avish Sood, JM The captioned appeals filed by the revenue are directed against the respective orders passed by the CIT(A)-47, Mumbai, for A.Y. 2012-13 and A.Y. 2014-15, which in turn arises from the respective orders passed by the A.O u/s. 271(1)(c) of the Act, dated 27.03.2019. As a common issue is involved in the present appeals, therefore, the same are being taken up and disposed off by way of....

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.... of the assessee was selected for scrutiny assessment u/s. 143(2) of the Act. 3. Assessment was framed by the A.O vide his order passed u/s. 143(3), dated 30.03.2015, wherein the income of the assessee company was assessed at Rs. 2,48,39,580/- after making the following additions: Sr. No. Particulars  Amount 1. Addition of bogus loans  Rs. 2,40,00,000/- 2. Addition on int....

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....as the impugned additions qua which the penalty was imposed by the A.O u/s. 271(1)(c) of the Act had been vacated by the Tribunal, therefore, the CIT(A) has rightly deleted the penalty that was imposed by the A.O u/s. 271(1)(c) of the Act. 8. Per contra, the ld. Departmental Representative (for short 'D.R') relied on the order of the A.O. It was submitted by the ld. D.R that the order pas....

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.... A.O cannot survive on a standalone basis and has to meet the same fate. On a perusal of the order of the CIT(A), we find that he had after taking cognizance of the fact that the impugned additions had been vacated by the Tribunal struck down the the penalty imposed by the A.O under Sec. 271(1)(c) of the Act, observing as under: "I have gone through the submission, order of the Hon'ble ITAT ....