2026 (5) TMI 901

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....it Aasudani, Sr. DR ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'CIT(A)'] dated 05/12/2025 passed u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for the Assessment Yea....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... on evidence on record, it ought to have been held that there is no under reporting of income within the meaning of section 270A of the Act, and hence the entire penalty ought to have been deleted. 4. The appellant craves liberty to add, alter, amend any ground of appeal." 3. The assessee in this appeal has contested the confirmation of penalty levied by the Assessing Officer of Rs. 9,....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the preliminary expenses claimed of Rs. 26,36,734/-. The assessee claimed the said expenditure being 20% of total preliminary expenses of Rs. 1,31,83,670/- u/s. 35D of the Income Tax Act. Herein also, the Assessing Officer has not disputed the incurring of expenditure, but only the eligibility of the assessee's claim of the said expenditure u/s 35D of the Income Tax Act. The Assessing Officer dis....