2024 (1) TMI 554

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.... and in law in confirming penalty of Rs. 5,55,622/- u/s 271(1)(c) of the Act for alleged furnishing of inaccurate particulars of income. 2. The Ld. CIT(A)-NFAC erred on facts and in law in not appreciating that the addition to the returned income is only on account of divergent interpretational view of different High Courts as to the admissibility of deduction admissible u/s 80P(2)(a)(i). 3. The Ld. CIT(A)-NFAC erred on facts and in law in not appreciating that the penalty on identical issue stand deleted by the CIT(A) for AY 2013-14 following Supreme Court in reliance Petroproducts Ltd. (210) 322 ITR 158 (SC) Total Tax Effect: 5,55,622/- ITA No. 890/Ahd/2023 A.Y. 2016-17 "1. The Ld. CIT(A)-NFAC erred ....

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....r assessment year 2014-15. The assessee is a co-operative society engaged in providing credit facilities to its members. The return of income for assessment year 2014-15 declaring total income at Rs. nil was filed by the assessee on 12-12- 2014 after claiming deduction u/s. 80P of the Act of Rs. 25,76,709/-. The assessment u/s. 143(3) was completed on 22-07-2016 disallowing deduction u/s. 80P of Rs. 25,39,105/. Penalty proceedings for levy of penalty u/s. 271(1)(c) were initiated in the assessment order and notice u/s. 274 r.w.s. 271(1)(c) was issued and served upon the assessee. After considering the decision of Hon'ble High Court in case of State Bank of India vs. CIT (2016) 72 taxmann.com 64. The Assessing Officer disallowed the deductio....