2026 (4) TMI 966

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....2025, was dismissed. 2. Assessee is aggrieved with the same and has raised several grounds of appeal contesting the levy of the penalty: a. The Hon'ble CT(Appeals), NFAC, Delhi has in the facts and circumstances of the case and in law erred in issuing the impugned Order dated 20 August 2025 under Section 250 of the Act confirming the penalty of INR 8,62,404 at the rate of 200% of the disputed demand imposed by the Learned AO under Section 270A of the Act for alleged under-reporting/mis-reporting of income. b. The Hon'ble CIT(Appeals), NFAC, Delhi has in the facts and circumstances of the case and in law erred in confirming the order of the Learned AO imposing penalty under Section 270A of the Act without mentioning the ....

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.... by the Hon'ble ITAT. g. The Hon'ble CIT(Appeals), NFAC, Delhi has in the facts and circumstances of the case and in law erred in not granting an opportunity of hearing to the Appellant and issued the impugned order in violation of the principles of natural justice. 3. The brief facts of the case shows that assessee is an individual employed with Ernst &Young LLP Indiafiled a return of income at a total income of Rs. 1,49,888. She has earned income outside India of Rs. 19,78,810. During assessment proceedings a question was raised about her claim of non-resident status and exemption of salary income earned in India as per Article 16(1) of the Double Taxation Avoidance Agreement. Same was not replied to by the assessee and assess....