2026 (2) TMI 1051

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....t, 1961 ["Act"], the assessee has filed this appeal on following grounds: "1. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the order passed by Assessing Officer without giving proper opportunity of being heard resulting into violation of principal of natural justice. 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the action of the Assessing Officer of imposing penalty of Rs. 30,000/- u/s 272A(1)(d) of the Act. 3. On facts and circumstances of the case and in law, the Ld. CIT(A) erred in upholding the action of the AO of imposition of penalty as appellant had reasonable cause for non-compliance of the impugned notices. ....

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....533 to 535/Ind/2025. (v) The present appeal being ITA No. 534/Ind/2025 is directed against the penalty imposed by AO u/s 272A(1)(d) for non-compliances to the notices u/s 142(1). The AO has passed penalty-order dated 25.09.2023 imposing a total penalty of Rs. 30,000/- @ Rs. 10,000/- for non-compliance of each of the three notices issued u/s 142(1). 3. At first, we note that the CIT(A) has dismissed assessee's first-appeal on the ground of delayed filing by 395 days. Similar delay [but with changes in days of delay] also happened in other two appeals, being ITA No. 533/Ind/2025 & 535/Ind/2025. This bench, vide two separate orders of even date authored by learned J.M., has taken a view to condone the delay in filing those appeals ....