2024 (9) TMI 859

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....Respondent : Shri P.D.Chougule(Addl.CIT) SR DR ORDER PER ANIKESH BANERJEE, J.M: Instant appeal of the assessee was filed against the order of the Learned National Faceless Appeal Centre (NFAC), Delhi [for brevity, 'Ld.CIT(A)'] passed under section 250 of the Income-tax Act, 1961 (in short, 'the Act'), for Assessment Year 2014-15, date of order 08.03.2024. The impugned order was emanated f....

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....her contend that the CIT(A) erred in upholding the action of the Assessing Officer in levying the impugned penalty inasmuch as the bona fides of the appellants cannot be doubted. The appellants crave leave to add to, alter or amend the aforestated ground of appeal." 3. The brief fact of the case is that the assessee is an AOP and maintaining a fund for the welfare of the Police of Maha....

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....e return filed under section 148 is duly accepted and the demand was Nil for the impugned assessment year. The Ld.AO initiated penalty proceedings under section 271(1)(c) of the Act. As the income was first identified by the revenue authorities on that basis, the penalty @100% being tax sought to be evaded amount to Rs. 1,08,56,103/- is levied. Being aggrieved on the penalty order, the assessee fi....

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....afide belief of the assessee that income is non-taxable, and TDS was deducted on income. Considering this question, the Ld.AR respectfully relied on the judgment of Hon'ble Bombay High Court in the case of CIT vs Sudhirkumar Chottubhai (2002) 120 Taxman 277 (Bombay) wherein the Hon'ble jurisdictional High Court accepted the bonafide belief of the assessee and the penalty was rejected and the order....