2025 (12) TMI 525

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....e Respondent : Shri Manish Gupta, Sr. DR ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for Assessment Year 2016-17 arises against National Faceless Appeal Centre/Commissioner of Income Tax (Appeals)[in short the "CIT(A)"], New Delhi's order dated 13.05.2025 passed in Case No. NFAC/2015-16/10125861 involving proceedings under section 271(1)(c) of the Income Tax Act, 1961 (herei....

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.... 3. It is in this background that both the learned lower authorities have held the assessee to have concealed and furnished its inaccurate particulars of income to levy section 271(1)(c) penalty. The Revenue could hardly dispute that both the impugned quantum disallowances have been made after rejecting the assessee's detailed explanation all along which could not be either termed as an instanc....