2026 (1) TMI 887

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.... (A)-1/DR ORDER PER : SUNIL KUMAR SINGH, JUDICIAL MEMBER: Both these appeals have been preferred by Revenue against two separate impugned orders each dated 24.01.2025 passed in Appeal No. CIT (A)-IV/KNP/10428 and CIT (A)-IV/KNP/10438 respectively by the Ld. Commissioner of Income-tax (Appeals)-4, Kanpur u/s. 250(6) of the Incometax Act, 1961 (hereinafter referred to as "the Act") for the ....

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.... proceedings under sections 271D and 271E of the Act for contravention of sections 269SS and 269T, respectively, and imposed penalties of Rs. 1,75,00,000/- and Rs. 1,19,60,000 vide separate orders each dated 29.05.2023, passed u/s. 271D and 271E of the Act. 3. Aggrieved, the assessee preferred appeals before the learned CIT(Appeals), who allowed the appeals and deleted the penalties on the grou....

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.....02.2025 passed in ITA No. 36 & 37/Agr/2024 for A.Yrs. 2015-16 & 2017-18. The impugned penalties were levied solely on the basis of those additions and were thus consequential in nature. Ld. CIT(Appeals) relied K.C. Builders vs. ACIT, 135 Taxman 461(SC), wherein Hon'ble Apex Court held that where the additions in the assessment order, on the basis of which penalty was levied, are deleted, there re....