2025 (11) TMI 904

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....e of assessee pertaining to Assessment Year 2015-16 is directed against the order dated 12.08.2024 of CIT(A), Pune-11 emanating out of Penalty order dated 03.09.2022 passed u/s.271(1)(b) of the Income Tax Act, 1961. 2. Registry has informed that there is delay of 306 days in filing the instant appeal before this Tribunal. Assessee has filed an affidavit explaining the reasons which led to delay....

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....l and engaged in the business of Mobile Shopee and deriving income therefrom. During the course of search and seizure action u/s.132 of the Act carried out in the case of M/s. Shri Renuka Mata Multi State Urban Cooperative Credit Society Ltd (in short 'RMMS', it was found that huge money was deposited by the assessee in the bank accounts held with 'RMMS' amounting to Rs.29.20 lakh. On verification....

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....l issue by filing additional ground challenging the validity of the penalty proceedings on the ground that the show cause notice issued u/s.274 r.w.s.271(1)(b) of the Act signed by digital signature which stood expired on the date of signing. 6. At the outset, Ld. Counsel for the assessee requested for not pressing the legal issue raised in the Additional Ground. The same is hereby dismissed as....

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....x Court on the limitation Cognizance for Extension of Limitation In re (2022) 441 ITR 722 (SC). 8. On the other hand, ld. DR supported the order of ld.CIT(A). 9. I have heard the rival submissions and perused the record placed before me. I observe that the assessee is an individual and assessment proceedings for A.Y. 2015-16 carried out u/s.147 r.w.s.144B of the Act. During the course of ass....