2026 (9) TMI 492

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....of the order passed by the Assessing Officer, ACIT, Circle-3, New Delhi (hereinafter referred to as 'ld. AO') passed u/s 271(1)(C) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') dated 05.03.2015. 2. The only issue to be decided in this appeal is as to whether the Learned CIT(A) was justified in deleting the levy of penalty under section 271(1)(c) of the Act in the sum of Rs 1,16,693 in the facts and circumstances of the instant case. 3. We have heard the rival submissions and perused the materials available on record. At the outset, we find that the penalty has been deleted by the Learned CIT(A) on the ground that the quantum additions were deleted by the learned CIT(A). The Learned DR before us stated that the qua....

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....opened HSBC bank account in Geneva. However, he did not admit having opened any bank account in HSBC Geneva on his own volition. During the post search proceedings, again the statement of the assessee was recorded under section 131 of the Act on 21-03-2012 and he reiterated the same contentions as were told in the statement under section 132(4) of the Act. 4. Further, a reference in this case was made to the appropriate authority for exchange of information through FT and TR with respect to the foreign bank account of the assessee. The first of such reference was made on 26-06-2012. The revenue before us was not able to bring any cogent evidence on record with regard to the status of such FT & TR reference as to whether any information w....