2026 (6) TMI 984

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....pondent : Shri Soumitra Ghosh, Add. CIT, Sr. DR ORDER PER YOGESH KUMAR U.S., JUDICIAL MEMBER This Appeal is filed by the Assessee against the order of the NFAC, Delhi (Appeal) ["the Ld. CIT(A)", for short], dated 14.11.2025passed u/s 250 of the Income Tax Act, 1961 ("the Act", for short) for the assessment year 2019-20. 2. The Brief facts of the case as stated in the order of the CIT(A....

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....urisdictional PCIT-9. Kolkata on 18.04.2024. Ld. PCIT-9, Kolkata has graciously disposed off the petition u/s 264 in favour of the appellant on 28.05.2024 and the entire addition was deleted. 4. Following the principle of merger, the Order u/s 147 dated 19.03.2024 for the assessment year 2019-20 has been merged with the Order u/s 264 of the Act on 28.05.2024 and therefore no addition u/s ....

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....as available or not and also ignoring the effect given consequent upon the Order u/s 264 by the Ld. JAO deleting the entire addition u/s 69A of the Act and imposed the penalty u/s 271AAC of the Act on the appellant." 3. Aggrieved by the order of the penalty passed u/s 271AAC(1) of the Act, Assessee preferred an Appeal before the Ld. CIT(A). However, the Ld. CIT(A) vide its order dated 14.11.202....

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....ed on 27.09.2024, which has been erroneously confirmed by the Ld. CIT(A) on 14.11.2025 vide order impugned. Thus, submitted that Appeal of the Assessee is allowed. 5. Per Contra, the Ld. DR relied on the orders of the Lower Authorities sought for dismissal of the Appeal. 6. We have heard the parties and perused the material on record. In the present case, an Assessment Order came to be passe....