2025 (4) TMI 1923

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.... For the Revenue : Shri Abhay Y. Marathe ORDER PER V. DURGA RAO, J.M. Appeal by the assessee is emanating from the impugned order dated 28/11/2024, passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, ["learned CIT(A)"], for the assessment year 2009-10. 2. The assessee has raised following grounds:- "1. Whether on the facts and ci....

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.... section 271(1)(c) of the Act was justified on account of disallowances of certain claims made during the course of assessment proceedings and more specifically in this case where the assessee is a District Central Co-operative Bank and the claim is pertaining to the deduction claimed by the assessee under section 36(1)(viia) of the Act. Before us, the learned Authorised Representative for the ass....

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.... must be satisfied that an Assessee has concealed income or furnished inaccurate particulars of income and only then can penalty be levied. A mere making of a claim, which by itself, is not sustainable under law would not amount to furnishing of inaccurate particulars of income. Therefore, as a matter of fact, since there was no finding by any authority that the details submitted by the Assessee c....