2026 (7) TMI 408

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ORDER UNDER SECTION 254(1) OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of learned Commissioner (Appeals)/ NFAC, dated 9thDecember 2025 for assessment year (AY) 2022- 23, in confirming the penalty levied under section 270A of Income Tax Act. Though, the assessee has raised multiple grounds of appeal, however, in our considered ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... was made by estimating income on ad hoc basis. In the alternative submission, the learned authorised representative of the assessee submits that in response to show cause notice issued by assessing officer for levying penalty under section 270A, the assessee filed application under section 270AA for seeking immunity from imposition of penalty. As per conditions prescribed in section 270AA, the as....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ue supported the order of lower authorities. On the alternative plea the learned senior departmental representative for the revenue submist that application for immunity was not filed as per time limit prescribed under section 270AA. 4. We have considered the rival submission of the parties and have gone through the orders of lower authorities carefully. On careful perusal of assessment order d....