2025 (3) TMI 1113

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....hri Anubhav Rastogi, Adv. For the Respondent : Shri Amit Katoch, Sr. D.R. ORDER PER VIMAL KUMAR, JM: 1. The appeal filed by assessee is against the order dated 09.10.2023 of Learned Commissioner of Income Tax (Appeals)- Income Tax Department, NFAC, Delhi [hereinafter referred to as 'Ld. CIT(A)'] arising out of penalty order dated 16.09.2021 passed by the National Faceless Assessment Ce....

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....er to avoid protracted litigation and buy peace. In the assessment order dated 24.12.2019 passed under section 143(3) of the Act, learned AO without pointing out any mistake in the original claim of the assessee and on basis of offer of additional disallowance accepted the additional disallowance of Rs. 7,62,56,056/-. Penalty proceedings under section 270A read with section 274 of the Act for unde....

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.... of PCIT vs. Caraf Builders & Constructions Pvt. Ltd. (2019) 101 taxmann.com 167 (Delhi) suo moto disallowed the expenses in earning exempt income and as such it cannot be inferred that the appellant has underreported the income. So the matter be referred back to the learned CIT(A). 6. Learned Departmental Representative for the Department of Revenue submitted that section 270AA(2) of the Act p....