2022 (9) TMI 838

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.... Assessment Year (A.Y) 2015-16. 2. The brief facts of the case is that the assessee is a Cooperative Society engaged in the business of supply of fertilizers, seeds, pesticides etc. to its members. The assessee society earns rental income and Dividend income from other Co-Op. Society. 2.1. During the course of assessment proceedings, The A.O. noticed that the assessee has earned rental income of Rs. 1,52,250/- and claimed deduction u/s. 80P(2)(d) of the Act on rental income which is not eligible for. Hence a show cause notice issued to disallow the claim of u/s. 80P(2)(d) of the Act on rental income. The assessee claimed statutory deduction u/s. 24 of the Act and accepted the addition of Rs. 1,06,575/- as the rental income. The A.O. i....

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....on. 2. The Ld. CIT(A) has erred in law and facts in confirming penalty U/s. 271(l)(c) of Rs. 32,932/- against the specific decisions of the Hon. Supreme Court and also of the Hon. Gujarat High Court though citen before him. Non acceptance of the same appears disregards towards judicial pronouncement. The penalty needs deletion. 3. The Ld. CIT(A) has erred in law and facts in confirming penalty U/s. 271(l)(c) of Rs. 32,932/- in respect of amount treated as income without proper verification and settled law. The penalty needs deletion 4. Without prejudice, no adequate and reasonable opportunity has been allowed at appeal stage. The penalty needs cancellation. 5. The Ld. CIT(A) has erred in law and facts in ....