2022 (11) TMI 1495

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....TURI RAMA RAO, AM: These are the appeals filed by the assessee directed against the separate orders of ld. Commissioner of Income Tax (Appeals)- National Faceless Appeal Centre (NFAC), Delhi ['the CIT(A)'] dated 01.09.2021 for the assessment years 2010-11 and 2012-13 respectively. 2. Since the identical facts and common issues are involved in both the above captioned appeals, we proceed to disp....

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....sh deposits amounting to Rs.1,48,43,428/- had escaped to the tax and, therefore, issued notice u/s 148 of the Income Tax Act, 1961 ('the Act') on 29.03.2017 after recording the reasons. Thereafter, assessment was completed by the Assessing Officer u/s 143(3) r.w.s. 147 of the Act dated 28.12.2018 at total income @ 8% of the cash deposits made by the appellant. Subsequently, the appellant was show-....

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....ed the levy of penalty. 6. Being aggrieved, the appellant is in appeal before us in the present appeal. 7. Having heard the rival submissions and perused the material on record, we are of the considered opinion that it is not fit case for levy of penalty u/s 271B merely because the appellant was unable to substantiate the submission that the appellant is only commission agent because there is no....