2024 (1) TMI 1178

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....ndent : None ORDER PER N. K. BILLAIYA, AM: This appeal by the revenue is preferred against the order of the CIT(A)-7, New Delhi dated 29.01.2019 pertaining to A.Y. 2009- 10. 2. The solitary grievance of the revenue is that the CIT(A) erred in deleting the penalty levied u/s. 271 (1)(c) of the Act. (a) On the issue of disallowance of Rs. 5,31,64,777/- made on account of valuati....

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....at Foreign buyers have insisted for best quality of iron ore fines and the stock of the assessee was not matching with the standards of the Foreign Buyers, therefore, the assessee could not sell the iron ore fines in domestic market and due to dust etc., the quantity of iron ore fine have deteriorated further. The explanation of assessee is supported by the fact that there is fall in export of iro....

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....t in assessment year under appeal by the assessing officer. However, this addition have been deleted by the Tribunal vide Order dated 22nd December 2017 and Order of the Tribunal is confirmed by the Honorable Delhi High Court. Therefore, the entire matter requires fresh reconsideration at the level of the assessing officer. We, accordingly, set aside the orders of the authorities below and restore....

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.... addition has been deleted by the Tribunal. The relevant findings read as under :- 17.1. Considering the totality of the facts and circumstances of the case, it is clear that assessee made suo motu disallowance under section 14A, but, assessing officer did not record any satisfaction as to how the disallowance made by the assessee was unreasonable or unsatisfactory. In the absence of any ....