2025 (9) TMI 889

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.... ORDER PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as 'the CIT(A)') dated 29.08.2024, for assessment year 2012-13 confirming penalty levied u/s. 271(1)(c) of the Income Tax Act,1961 (hereinafter referred to as 'the Act'). 2. Shri Somil Aggar....

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....e penalty. 4. Both sides heard. A bare perusal of assessment order reveals that satisfaction has been recorded by the AO for initiating penalty u/s. 271(1)(c) of the Act on the charge of concealment of income. Whereas, penalty has been levied by the AO vide order dated 30.08.2021 for furnishing inaccurate particulars. There is no coherence in invoking charge while recording satisfaction and at ....