2025 (5) TMI 1092

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.... Sr. DR ORDER 1. The assessee has filed this appeal against the order of the Learned Commissioner of Income Tax (Appeals)-23, New Delhi ["Ld. CIT(A)", for short] dated 11.07.2023 for the Assessment Year 2014-15. 2. At the time of hearing, ld. AR of the assessee submitted that the appeal filed by the assessee is against imposition of penalty under section 271(1)(c) of the Income-tax Act, 1....

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....ge 12 of the paper book which is the original return of income filed by the assessee declaring loss of Rs. 15,41,784/- and he also brought to my notice page 15 of the paper book which is the revised return of income filed on 29.03.2023. He prayed that the imposition of penalty u/s 271(1)(c) be deleted and he relied on the following case laws :- (i) Delhi ITAT in the case of Toscana Lasts ....

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.... by the assessee in the ITR filed u/s 148 1,05,82,796/- (v) Addition on account of disallowance of expenses of Rs.96,84,734 96,84,734/- (suo moto disallowed)   Addition on account of disallowance u/s 14A of the Act 1,56,583/- (suo moto disallowed)   Addition on account of late deposit of TDS/ST 1,28,064/- (suo moto disallowed) (vi) Any other adjustment....

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....med carried forward of loss and reduced the voluntary disallowance of expenses for which the reassessment proceedings were initiated on the behest of audit objection. We observed that when the assessee has chose not to carry forward the returned losses to future assessment years, the reduction in such amount which the assessee chose not to carry forward, the adjusted losses have no impact on the t....