2025 (10) TMI 1303

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....rivastava, Sr.DR ORDER PER S.RIFAUR RAHMAN, AM: 1. This appeal is filed by the assessee against the order of ld. Commissioner of Income-tax Appeals/National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. CIT (A)] dated10.06.2025 for Assessment Year2014-15 affirming the penalty order dated 15.02.2022 passed under section 271(1)(c) of the Income tax Act, 1961 (for sho....

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....eof. Hence the Assessing officer had completed the assessment u/s 143(3) on 24.12.2016 after rejecting the books of account u/s 145(3) and computed the assessee's total income at Rs. 56,90,124/- estimating the income from contract work @ 8%. 3. After completion of the assessment u/s 143(3) dt. 24.12.2016, the Assessing officer had passed a revision order u/s 154 on 02.05.2018 by disallowing....

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....inst the revision order passed u/s 154 on 02.05.2018 before the ld.CIT(A) who had deleted the addition vide his order dated 31.07.2019. Accordingly, the Assessing officer had passed a revision order on 17.09.2019 by giving effect to the CIT(A)'s order and revised the assessee's total income at Rs. 47,44,875/-. Accordingly, in the penalty proceedings, the AO observed that the assessee had c....

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....rs of the lower authorities. 6. Considered the rival submissions and material placed on record. We observe that the AO made the addition on estimate basis @ 8% and the ld. CIT (A) reduced the same also on estimation basis @ 7%.. We observe that the Assessing Officer made the penalty u/s 271(1)(c) of the Act@ 100% tax sought to be evaded i.e. Rs. 1,68,789. which was sustained by the ld. CIT (A).....