2024 (7) TMI 36

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....al has been filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi ['CIT(A)' in short] dated 12.02.2024 arising from the penalty order dated 17.02.2017 passed by the Assessing Officer (AO) under Section 271(1)(c) of the Income Tax Act, 1961 (the Act) concerning A.Y. 2014-15. 2. As per the grounds of appeal, the assessee ....

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....ition of penalty has been altered by the AO himself. The penalty has been imposed on a different premise than the original satisfaction derived for imposition of penalty. 5. Needless to say, the imposition of penalty is dependent upon the 'satisfaction' derived by the AO. The ground for initiation of action by the AO under Section 271(1)(c) was allegation of 'furnishing of inaccurate particular....