2025 (8) TMI 1331

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....e Act'). 2. The brief facts of the case are that the assessee had filed his return of income for the A.Y. 2013-14 on 16.08.2013 declaring income of Rs. 3,72,342/-. The case was subsequently reopened under Section 147 of the Act and a notice under Section 148 of the Act was issued on 31.03.2020. There was no compliance to the said notice. Further, subsequent notices issued under Section 142(1) of the Act by the AO were also not complied by the assessee. Though the assessee had sought adjournment in response to the first notice u/s 142(1) of the Act dated 03.01.2021, no compliance was made to the subsequent two notices issued on 31.03.2021 and 16.08.2021. The assessment was completed u/s 147 r.w.s. 144 of the Act on 25.09.2025 at a total inc....

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....he Act was duly complied and an adjournment application was filed. However, no compliance could be made to the subsequent notices issued on 31.03.2021 and 16.08.2021 due to prevailing Corona pandemic. He further submitted that Ld. CIT(A) was not correct in dismissing the appeal on the ground of delay without adjudicating the appeal on merits. The Ld. AR further submitted that the Assessing Officer was not correct in imposing penalty of Rs. 20,000/- for the two failures on the part of the assessee without initiating two separate penalty proceeding. 6. Per contra, Shri Abhijit, Ld. Sr. DR, submitted that the assessee was well aware of the fact about the assessment proceedings and the notices were also received by him. In fact, compliance was....