2025 (3) TMI 1861

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....lwal For the Respondent : Shri Alok Kumar ORDER PER JUSTICE (RETD.) C.V. BHADANG, PRESIDENT : By this appeal, the appellant-assessee is challenging the order dated 31.12.2024 passed by the Commissioner of Income Tax (Appeals)-49, Mumbai ('CIT(A)' for short) by which the imposition of penalty under Section 271(1)(c) of the Income Tax Act, 1961 ('Act' for short) to the extent of the quan....

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....68 of the Act, only an addition to the extent of Rs. 2,32,23,158/- has been sustained by the Tribunal by deleting the balance addition of Rs. 12,51,94,466/-. The additions under other heads have also been deleted. The CIT(A) has, therefore, directed the Assessing Officer to recompute the penalty accordingly. To that extent, the appeal has been partly allowed by the learned CIT(A). 4. The assess....

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....IT, 434 ITR 1 (Bombay). 7. The learned AR has produced details of addition under Section 68 of the Act on which the penalty is levied by the Assessing Officer by order dated 30.03.2019. It is submitted that out of the addition in relation to nine parties, only four relating to (i) Raj Mittal, (ii) Sushil C. Choksi, (iii) Adinath Textiles and (iv) Fortune Financial Services (I) Ltd. have been co....

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....rder of the Assessing Officer imposing penalty refers to a subsequent notice dated 12.01.2006, a copy of the same has not been produced by the Revenue. A perusal of the impugned order shows that the learned CIT(A) vide letter dated 25.10.2021 had asked the Assessing Officer to clarify whether any notice subsequent to notice dated 31.10.2002 was issued in the matter. The order records that the repo....