2025 (2) TMI 1406

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....rs. The details of impugned assessment orders and appellate order passed in the aforesaid cases of the assessee's are as under: Trimurthi Finvest Ltd. ITA No. AY Date of AO's order Date of CIT(A)'s order U/s Amount of penalty imposed ITA 254/RPR/2024 2017-18 21.11.2019 20.02.2024 272A 10000 ITA 256/RPR/2024 2018-19 23.03.2022 20.02.2024 272A 20000 ITA 258/RPR/2024 2019-20 23.03.2022 20.02.2024 272A 20000 Purvi Finvest Ltd. ITA 268/RPR/2024 2018-19 31.03.2022 20.02.2024 272A 30000 2. Briefly stated, the assessee companies, which are registered as a nonbanking financial corporation, mainly dealing in the business of providing unsecured l....

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....(1)(d) is illegal and unjustified and, therefore, penalty imposed should be deleted & that under the facts and circumstances of the case the penalty u/s 272A(1)(d) levied on the assessee is unreasonable, illogical and against the interest of natural justice." No explanation has been furnished by the appellant at this stage on the findings and conclusion of the Id. AO. In absence of any explanation & on the basis of facts gathered and discussed by the Id. AO, considering entire facts in the penalty order, I find that Id. AO is justified in passing penalty order as discussed above. I have considered the facts of the penalty order and found that "it is evident from the above details that the Id. AO has provided opportunity to the asse....

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....sed without affording opportunities of being heard against the principle of natural justice, therefore, the same are arbitrary and illegal, thus, needs to be deleted. 5. Per contra, Shri S. L. Anuragi, CIT-DR and Dr. Priyanka Patel, Sr. DR representing the revenue placed their strong reliance on the orders of revenue authorities and requested to uphold the same, as the assessee's conduct before the both the authorities was evasive and that of a persistent non-compliant, therefore, the penalties imposed are well as per the mandate of law, deserves to be sustained. 6. We have considered the rival submissions and have perused the material available on record. After hearing from both the parties, we find that the assessee remains non atte....