2025 (2) TMI 1375

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....R.R. Makwana, Addl. CIT ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the Revenue against order dated 17/04/2024 passed by NFAC, Delhi in relation to penalty proceedings u/s. 271(1)(c). 2. The Revenue is aggrieved by deletion of penalty of Rs. 3,00,58,858/- which was levied by the ld. AO on the income offered by the assessee in the return of income filed u/s.139(4....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....total consideration of Rs. 5.62 Crores received for sale of land over as capital gain in his regular return of income for the A.Y.2012-13. 4. In the assessment order, ld. AO held that Investigation Wing of the Income Tax department detected certain transaction of sale of land undertaken by the assessee and it is only after the detection by the investigation wing, assessee has disclosed said tra....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s in respect to adhoc disallowance of expenses and disallowance on account of depreciation. No way, the ld. AO has found that assessee has furnished any inaccurate particulars of income during the course of assessment proceedings. It is also not brought on record that it is only the enquiry conducted by the Investigation department which prompted assessee to offer short term capital gain but the f....