2025 (3) TMI 92

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.... For the Revenue : Shri Rignesh Das, 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 ....

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....uments required to raise objection for validity of re-opening 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 Object....

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....s. 144 r.w.s. 144B of the Act 2.1. The Ld. AO held that there is failure of compliance to notice issued u/s. 142(1) of the Act dated 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....

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....llegal as it being time barred. 5. The Ld. CIT (A) has erred in law and on facts in upholding penalty levied by the Ld. AO as assessment proceedings initiated by 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....