2025 (9) TMI 840

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....RDER 1. The appeal in ITA No.310/AGR/2025 for AY 2018-19, arises out of the National Faceless Appeal Centre, Delhi [hereinafter referred to as 'ld. CIT(A)', in short] in Appeal No. NFAC/2017-1810292998 dated 30.04.2025 against the order of assessment passed u/s 147 r.w.s. 144/144B of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 13.03.2022 by the Assessment Unit (hereina....

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....ure are accumulated over the years and such surplus had been ploughed back to the coffers of the Assessee University for educational purposes. The Assessee University had received direct grant from the Government of Uttar Pradesh at the time of formation of University whereby land and expenditure incurred to create building, other infrastructure facilities etc was wholly funded by Government of Ut....

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....t of the Assessee in furnishing the requisite information before the Learned AO, but ultimately all the details relevant for framing of assessment had indeed been filed by the Assessee University before the completion of assessment proceedings which fact is also admitted by the Learned AO in page 3 of his order. But still penalty was initiated and levied by the Learned AO under section 272A(1)(d) ....

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....ust v ADIT reported in 115 TTJ 419. Similar view was also taken by the Coordinate Bench of Raipur Tribunal in the case of Mrs. Bhavna Modi v ITO in ITA No. 298 /Rpr/ /2024 for assessment year 20-21 and Coordinate Bench of Cochin Tribunal in the case of Jomon John v NFAC in ITA No. 578/ Coch / 2024 for assessment year 2017-18 dated 29-04-2025. 4. In view of my aforesaid observations and respectf....