2026 (5) TMI 1138

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....t Kaur Hansra, Sr. DR ORDER PER AMITABH SHUKLA, AM, The captioned appeal has been preferred by the assessee against order dated 08.10.2025 of the Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre, New Delhi,[hereinafter referred to as 'ld. CIT(A)'] arising out of assessment order dated 27.06.2019 passed u/s 271(1)(c) of the Income Tax Act, 1961 pertaining to Assessment....

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.... by imposing the penalty on difference of presentation of figures by the assessee in the Income Tax Return and Tax Audit Report as the penalty has been imposed on difference of opinion between the Ld. AO and the appellant on presentation of figures and hence, in such case the penalty cannot be levied for the concealment of income or furnishing the inaccurate particulars of income and Ld. CIT(A) ha....

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....ve intent. 3. The only issue seminal to the present appeal is regarding the imposition of penalty u/s 271(1)(c) of the Act. The ld. Counsel for the assessee submitted that the penalty imposed upon the assessee of Rs. 92,267/- is totally untenable. It was submitted that no addition has been made in the assessment order. The ld. Counsel of the assessee has argued that the Return of Income of Rs. ....