2025 (11) TMI 1774

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....venue, the impugned order of the ITAT gives rise to the following substantial question of law:- "1. Whether on facts and circumstances of the case and in law, Hon'ble ITAT erred in deleting penalty under section 271(1)(c) of the Income Tax Act 1961 without appreciating the fact that assessee has concealed particulars of income and has furnished inaccurate particulars of income during the assessment proceedings." 2. In the facts of the present case, the Assessee filed its Return of Income on 14th November 2007 declaring a loss of Rs. 95,46,150/-. The case of the Appellant was selected for scrutiny and an order under Section 143 (3) was passed on 30th December 2009 by making certain additions which inter alia included (a) an addit....

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....enue filed Income Tax Appeal No.18 of 2019. In that Appeal, the only ground taken to challenge the order of the ITAT was that the ITAT was incorrect in allowing the deduction under Section 10A to the Assessee. In other words, in the said Appeal, the finding of the ITAT that the amount of Rs.1.79 Crores expended by the Assessee was really revenue in nature, was not challenged before this Court. 4. The order of the ITAT insofar as it allowed the deduction under Section 10A to the Assessee was upheld by this Court vide its order dated 13th November 2025 (passed in ITXA 18 of 2019). Hence, as far as the issue of the deduction claimed under Section 10A is concerned, the same has been confirmed all the way to this Court. As far as the issue of....