2025 (3) TMI 1967

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....PER AMITABH SHUKLA, AM: This appeal by Assessee is directed against the order of National Faceless Appeal Centre, Delhi, [for short hereinafter referred to as the ["Ld. CIT(A)"] dated 28.06.2024 for Assessment Year 2017-18. 2.0 It has been noted that there is a delay of 77 days in the case, in filing of this appeal before the tribunal. In its affidavit the assessee has pleaded that the asses....

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.... issue seminal to the controversy is incorrect impositions of penalty under section 271A by the Ld. AO and its affirmation by the Ld. CIT(A).The Ld. Council for the assessee submitted that there have been several deficiencies, in the entire issue of imposition of penalty under section 271A in its case which have made the same per se bad in law. The Ld. Council pointed that neither the penalty noti....