2025 (3) TMI 92

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...., Sr. D.R. ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee as against order dated 28.06.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as "CIT(A)"), confirming levied penalty of Rs. 30,000/- under section 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for ....

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.... of assessment 12.11.2021 Notice U/s 143(2) of the Act alongwith Extract of reasons 15.11.2021 Reminder letter to provide documents to raise objection for validity of reopening of assessment 17.11.2021 Reminder letter to provide documents to raise objection for validity of reopening of assessment 24.11.2021 Objection filed against the reopening of assessment proceedings 27.05.2022 Notice....

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....ated 19.04.2023, 28.04.2023 and 06.05.2023 and therefore levied penalty u/s. 271(1)(b) of Rs. 30,000/-. 3. Per contra, the assessee submitted that there is no failure on the part of the assessee to comply with the statutory notices, whereas the A.O. has not provided the documents as requested by the assessee repeatedly. On Appeal, the assessee requested to delete the penalty which was not accepte....

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.... the Ld. AO is without jurisdiction hence all the subsequent notices and penalty proceedings are also void and illegal 6. The Ld. CIT(A) has erred in law and on facts in upholding penalty levied by the Ld. AO U/S 271(1)(b) of the Act of Rs. 30,000/- for vague non-compliance of notices issued U/S 142(1) of the Act 7. The appellant Craves liberty to add, amend, alter or modify all or any grounds....