2025 (6) TMI 1467

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ta, Sr. DR ORDER PER YOGESH KUMAR, U.S. JM: The Assessee has challenged the order of Ld. CIT (A) dated 10/04/2024 wherein the Ld. CIT(A) confirmed the order of penalty passed by the A.O. u/s 270A of the Act for Assessment Year 2018-19. 2. Brief facts of the case are that, the Assessee had not filed the Income Tax Return on time. However, filed return of income on 11/04/2022 declaring total inc....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....9/2024, the Assessee preferred the present Appeal. 4. The Ld. Counsel for the Assessee submitted that the Assessee has voluntarily filed the return of income and the same has been accepted by the Department, there is no case of 'under reporting the income' as no addition has been made by the A.O. for the year under consideration. Further, submitted that the Ld. CIT(A) has committed error in dismi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... year under consideration belatedly declaring total income of Rs. 1,02,88,060/- and the assessment has been completed at the return income. While passing the assessment order a satisfaction has been recorded by the A.O. for 'under reporting the income'. Consequent to the said satisfaction, penalty proceedings u/s 270A has been initiated for 'under reporting the income' and penalty has been imposed....