2025 (7) TMI 306

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....v. For the Department : Shri Om Prakash, Sr. DR ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The appeal of assessee is against order dated 15.07.2024 of Learned Commissioner of Incom-Tax (Appeals)/National Faceless Appeal Centre (National Faceless Assessment Centre (NFAC)), Delhi (hereinafter referred as "Ld. CIT(A)" under Section 250 of the Income Tax Act, 1961 (hereinafter referred as "th....

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.... 27.12.2017, Shri Yash Berry, CA & AR appeared for hearing with basic financials of the assessee. On completion of proceedings, Ld. AO passed assessment order dated 30.12.2017. Separate penalty proceedings were initiated. Show-cause-notices for penalty under Section 271(1)(c) of the Act dated 28.02.2019 and 17.03.2022 were issued. On conclusion of penalty proceedings, Ld. AO passed penalty order d....

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....as held by Hon'ble Supreme Court in CIT vs. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 (SC). 6. Learned Authorized Representative for Revenue relied on orders of Departmental Authorities. 7. From examination of record in light of aforesaid rival contentions, it is crystal clear that penalty order dated 31.03.2022 under Section 271(1)(c) of the Act is in pursuance to assessment or....