2025 (2) TMI 1380

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....he Act') for the A.Y. 2013-14. 2. In the instant case, the Assessee by filing its return of income on dated 28.08.2023 declared total income at Rs. 78,50,014/- including ESOP perquisite value of Rs. 72,84,320/- and claimed the refund to the tune of Rs. 21,46,410/-. The Assessee also claimed the relief amounting to Rs. 20,44,855/- u/s 90 of the Act, as observed by the Assessing Officer (AO) from the schedule TR of the ITR-2 submitted on dated 09.10.2014 during the course of scrutiny proceedings and therefore in order to verify, the statutory notices were issued to the Assessee and ultimately the assessment was completed u/s 143(3) of the Act by passing assessment order dated 31.03.2016, whereby the relief claimed u/s 90 of the Act on ....

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....ssment year under consideration, denied the Assessee's claim u/s 90A of the Act on account of ESOP requisite to the tune of Rs. 20,44,855/- and recorded the satisfaction and simultaneously initiated the penalty proceeding for furnishing inaccurate particulars of income and concealing the taxable income. Thereafter the AO issued a show cause notice of penalty proceedings u/s 271(1)(c) of the Act by highlighting the limb i.e. concealment of particulars of income. Thereafter the AO issued another notice dated 25.03.2019 for penalty proceedings u/s 271(1)(c) of the Act but without mentioning any of the limbs as specified u/s 271(1)(c) of the Act. The AO thus therefore vide penalty order dated 31.03.2019 ultimately levied the penalty of Rs. ....