2025 (3) TMI 1883

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 2014-15, 2015-16 & 2016-17. These appeals are heard together and for the sake of convenience we are adjudicating all the appeals together by passing a common order. 2. The following grounds of appeal are raised by the assessee: a) The penalty order is bad in law and against the principles of natural justice. b) The appellant had reasonable cause u/s.273B for non-compliance. c) Erroneous interpretation of law in levying separate penalties for multiple notices. d) The penalty is disproportionate and fails to consider mitigating factors. e) Violation of natural justice and procedural fairness. 3. At the outset, we find that there is a delay of 127 days in all the three appeals filed by 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

....hree assessment years by passing an order as detailed below: Asst. Year Date of Penalty Order Penalty 2014-15 19/09/2022 Rs. 30,000/- 2015-16 19/09/2022 Rs. 30,000/- 2016-17 22/09/2022 Rs. 20,000/- Aggrieved by the order of the AO, the assessee preferred an appeal before the ld. CIT(A), NFAC, Delhi. 6. After considering submission made by the assessee the ld. CIT(A) passed a separate three orders dated 01.05.2024 and partly allowed the appeal of the assessee as detailed below: Asst. Year Date of Penalty Order Penalty 2014-15 01/05/2024 Rs. 10,000/- 2015-16 01/05/2024 Rs. 20,000/- 2016-17 01/05/2024 Rs. 10,000/- Aggrieved by the order of the ld. CIT(A), the asse....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... for all the three assessment years at Rs. 30,000/- Rs. 30,000/- and Rs. 20,000/- respectively. On appeal to the ld.CIT(A), the penalty has been reduced to Rs. 10,000/- Rs. 20,000/- and Rs. 10,000/- for A.Ys. 2014-15, 2015-16 & 2016-17 respectively, finding that there was reasonable cause for non-compliance of the few notices. On perusal of notices issued by the AO during the assessment proceedings, we find that there was a huge impact of Pandemic Covid 19 in the entire nation during that period and the ld.CIT(A) has considered the non-compliances had 'reasonable cause' on account of Covid 19 for few notices and deleted the penalty and sustained the balance penalty for few notices, even though all the notices were issued during the existenc....