2025 (9) TMI 701

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.... The Appellant : None For The Respondent : Ms. Pratibha Meena, Sr.DR ORDER PER AVDHESH KUMAR MISHRA, AM Common grounds and facts arise in the above captioned appeals of the assessee; therefore, these appeals were heard together and are being disposed off by this common order. 2. These appeals for the Assessment Years (hereinafter, the 'AY') 2017- 18, 2018-19, 2019-20 and 2020-21 res....

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.... detailed in the penalty orders. The Ld. Sr. DR, placing reliance on the finding of the Ld. CIT(A), submitted that the penalty orders and impugned appellate orders clearly demonstrated that the assessee had made non-compliance in a tactical way to avoid investigations. 5. We have heard the Sr. DR and perused the material available on records. It is evident from the records of these cases that t....

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....hin the reasonable time period from the date of non-compliance of each notice separately. In such circumstances, the penalty would have been levied within the specified period of six months from the end of month in which the same was initiated as such default has nothing to do with the quantum appeal. Thus, we do not see any justification on the part of the AO that why there was delay in initiatin....

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....ee would have not ensured compliances thereafter. The purpose of issuing notice for non-compliance of statutory notices within the reasonable time of default would have served the purpose of the AO. The initiation of penalty proceedings after completion of the assessments in all four years, clearly indicate that the AO was not inclined in ensuring the compliance not through deterrent effects of pe....