2025 (2) TMI 1463

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....R For the Assessee Represented : Shri Tushar Hemani, Sr. Advocate For the Revenue Represented : Shri Ravindra, Sr.D.R. ORDER PER : DR. BRR KUMAR, VICE PRESIDENT: Delay Condoned This appeal is filed by the Assessee as against the appellate order dated 28.06.2024 passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, relating to the Assessment Ye....

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....e initiated. 2. The Appellant is very much confident of getting a favourable decision in the Quantum Appeal, which is pending before the NFAC. It is pertinent to mention that when the hearing of the Appeal filed by the Appellant against the penalty order before the NFAC came up for hearing unfortunately because of the fact that the erstwhile Ashima Dyecot Private Limited was merged into t....

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....f income in case of the Appellant and thus the Ld. AO has erred in law and on facts in levying penalty of Rs. 8,70,482/- u/s 270A of the Act, which is required to be deleted. 4. The Appellant craves to add. amend and/or alter the ground or grounds of appeal either before or at the time of hearing of the appeal. 3. For the year under consideration, the Appellant Company - erstwhile Tran....

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.... 4. The Appellant Transferee Company Ashima Limited has filed an appeal before the National Faceless Appeal Centre (NFAC) on 19.01.2022 both on technical grounds as well as on merits contending that at the outset the Assessment Order made u/s 143(3) of the Act in the name of the erstwhile Transferor Company, Ashima Dyecot Private Limited is bad in law since it was made in the name of the Company,....