2026 (4) TMI 1773

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....l.CIT- DR ORDER PER PAVAN KUMAR GADALE, JM: The assessee has filed an appeal against the order of CIT(A) passed u/sec 250 of the Income Tax Act, 1961.The assessee has raised the grounds of appeal challenging the order of the CIT(A) sustaining the levy of penalty u/sec 270A of the Act made by the Assessing officer. 2. The brief facts of the case are that, the assessee has filed the retu....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ngs u/sec 270A of the Act for under reporting of income and the A.O has issued show cause notice. The assessee has complied with the information and explanations vide letter dated 8.03.2025&16.03.2025, the contentions of the Ld.AR that the additional income is offered to tax by the assessee before the issue of notice u/sec148 of the Act and paid the taxes and the A.O has accepted the return of inc....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... levied as the additional income is offered to tax by the assessee before the issue of notice u/sec148 of the Act and paid the taxes Further the Ld. AR emphasized that the assessee in response to notice under Section 270A of the Act dated 17- 03-2021 has submitted the explanations along with the details through E-Portal of the ITBA and the Assessing Officer has overlooked the submissions The Ld.AR....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....onal income is offered to tax by the assessee before the issue of notice u/sec148 of the Act and paid the taxes. The Ld. AR emphasized that the assessee has paid additional tax @ 25% on the additional income and referred to the updated return of income u/sec 139(8A) of the Act filed on 23.01.2023 placed at page 06 to 11 of the paper book. Further, the Ld. AR's contentions are that penalty provisio....