TaxTMI 
TaxTMI 
2026 (9) TMI 609
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....mar, Sr. DR ORDER PER : SUCHITRA KAMBLE, J M: The appeal filed by the assessee is against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short "CIT(A)"] dated 22.09.2025 for the Assessment Year (in short "AY") 2016-17. 2. The assessee has raised the following grounds of appeal: "1. On the facts and circumstances....
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.... dated 20.12.2018. Accordingly, Assessing Officer (in short "the AO") initiated applicable concealment penalty proceedings as applicable u/s. 271(1)(c) of Income Tax Act, 1961 (in short "the Act") along with this assessment order and concluded the same by levying such penalty as explained and reasoned in detail in the penalty order u/s. 271(1)(c) of Act dated 28.06.2019. Further during the scrutin....
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....ing assessee's substantiations on such non applicability of these provisions as pertains to 12 such transactions involving non compliances to file form 15CA before AO for its reconciliation/verification as per law. In the absence of such substantiations as reasoned by AO, AO observed that assessee has squarely attracted by these applicable penalty proceedings as pertains to such 12 transactions an....
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....t to a non-resident, not being a company, or to a foreign company came in force on 1st day of April, 2016. Thus, the Form 15CA/Form 15CB related to information related to foreign remittance could not be filed within the stipulated time. The Ld. AR submitted that the Tribunal in case of Gopal Chandak vs. ACIT (ITA No.904/SRT/2024 dated 27.05.2025 has categorically held that the assessee is under bo....