2022 (3) TMI 900

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rmed the order of the AO imposing penalty on the assessee under section 271(1)(c) of the Income Tax Act, 1961 (hereinafter called 'the Act'). 2. The assessee is a salaried employee with M/s SAP Labs India Pvt Ltd ('the company'). For Assessment Year 2015-16, the assessee filed revised return of income on 08.03.2016 vide acknowledgement No. 974743380080316 declaring a total income of Rs. 14,94,830/- which was arrived after claiming loss under the head Income from House Property to the extent of Rs. 6,85,235/- and Chapter VI-A deduction to the extent of Rs. 2,83,039/. Accordingly, a refund of Rs. 2,28,340/- was claimed in the ROI. The return was processed under u/s 143(1) on 13.04.2016 and a refund of Rs. 2,35,190/- was issued. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s arrived by the AO. The assessee did not appeal against the order to buy peace and paid the demand raised in the notice of demand u/s 156 vide challan dated 27.11.2019. 5. The AO also initiated penalty proceedings u/s 271(1)(c) of the Act by issuing notice u/s 274 r.w.s 271 of the Act on 13.11.2019. In response to the above notice, the assessee vide letter dated 02.12.2019 submitted that in the interest of equity and justice considering the facts and circumstances under which assessee has filed the original return lenient view was requested before the AO along with citations of case laws. However, the AO rejected the submissions of the assessee and passed order u/s 271(1)(c) of the Act on 03.02.2020. In the order, the AO concluded that ....