2025 (9) TMI 357

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....pondent : Shri V K Mangla, Sr. DR ORDER PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: Both the appeals have been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short "Ld. CIT(A)"), National Faceless Appeal Centre (in short "NFAC"), Delhi vide order dated 23.08.2024 passed for A.Ys. 2012-13 & 2013-14. Since the common facts and issued are i....

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....observed that on examination of records it was found that the assessee was receiving monthly salary from M/s. Blue Dart Express Ltd. and the assessee had filed return of income declaring salary income only. Therefore, the Assessing Officer issued several notices of hearing asking the assessee to explain the source of expenditure. The assesseee, vide email dated 08.12.2017 informed the Assessing Of....

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....otices issued under Section 142(1) of the Act. 5. The assessee is in appeal before us, against the order passed by Ld. CIT(A) confirming the levy of penalty under Section 271(1)(b) of the Act. 6. In case of Vedabai vs. Shantaram Baburao Patil 253 ITR 798 (SC), the Hon'ble Supreme Court held that the expression "reasonable cause" should be construed liberally so as to advance substantial just....

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.... notice under Section 143(2) by assessee, and, therefore, penalty under Section 271(1)(b) cannot be imposed. 9. In the case of Smt. Rekha Rani vs. Deputy Commissioner of Income-tax, Central Circle-8, New Delhi [2015] 60 taxmann.com 131 (Delhi - Trib.)/[2015] 154 ITD 617 (Delhi - Trib.)[06-05-2015], the ITAT held that penalty under Section 271(1)(b) cannot be imposed for each and every notice is....