2026 (3) TMI 1416

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....ioner: Mr. P. J. Pardiwalla, Sr. Advocate with Adv. Dharan V. Gandhi and Ms. Aanchal Vyas,. For the Respondents: Adv. Shilpa Goyal,. P.C. 1. The above Writ Petition challenges the initiation of penalty proceedings in the Order under Section 92CA(3) of the Income Tax Act, 1961 (the "IT Act") dated 20th January, 2025; initiation of penalty in the final Assessment Order dated 24th March, 202....

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....nsel appearing on behalf of the Revenue, took a preliminary objection and stated that the issue of jurisdiction as well as on merits can be agitated by the Petitioner before the CIT(A) as the penalty order passed is an appealable order under Section 246A of the Act. 4. Faced with this preliminary objection, Mr. Pardiwalla, the learned Senior Advocate appearing on behalf of the Petitioner, on ta....

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....d by the Petitioner within a period of three weeks from today, the CIT (A) shall entertain the Appeal of the Petitioner on merits without raising the issue of limitation. In other words, if the Appeal is filed by the Petitioner within a period of three weeks from today, the delay in filing the Appeal is hereby condoned. 7. Further, since the issue whether the Transfer Pricing Officer would have....