2025 (7) TMI 20

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.... For The Assessee : Mr. Rajeev Waglay For The Revenue : Ms. Deepa Hiray, Sr. DR ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated 13.03.2025 passed by the Ld. Commissioner of Income-tax (Appeals) - National Faceless Appeal Centre, Delhi [in short 'the Ld. CIT(A)'] for assessment year 2018-19, raising following grounds: "ON THE FACTS AND ....

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....he Appellant vide response dated 28.5.2021 duly uploaded. (para 7 of the said letter) (b) various case laws mentioned in the grounds of appeal laying down that penalty proceedings cannot be initiated/continued against the dead person. (c) the fact that legal heirs cannot be implicated in respect of penalty proceedings against the dead person. And hence, the order dated 1....

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....ssing officer, he passed the impugned order on 26.08.2021 for levy penalty u/s 270A of the Act amounting to Rs. 70,31,812/-. The Ld. CIT(A) though acknowledged the fact of the death of the assessee, however sent the matter back to the Assessing officer observing as under "IV. Since the assessee is dead the legal heir has to be implicated. For that purpose an order has to passed immediatel....