TaxTMI 
TaxTMI 
2026 (6) TMI 1514
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..../s 147 r.w.s 144 read with section 144B of the Income-tax Act, 1961 (hereinafter referred to as the "Act"), dated 17.06.2024 for the Assessment Year 2019-20. 2. Assessee has raised the following grounds of appeal: i. On the facts and in the circumstance of the case the learned Commissioner of Income tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, erred in confirming the order of the Assessment Unit, Income tax Department in respect of penalty under section 270A of the Act amounting to Rs. 1,87,200/- being 200% of the tax on under reporting income which is in consequence of misreporting thereof without referring of any of the clauses of section 270A(9) of the Act. ii. On the facts and in the circumstance of....
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....d made donation to political party and claimed deduction under section 80GGC of Rs. 3,00,000/-. 4. In the course of assessment proceedings, assessee furnished his reply in respect of the claim of deduction by furnishing copies of donation receipts of Rs. 2,00,000/- and Rs. 1,00,000/-. He made a detailed submission explaining his case for the donation made by him and deduction so claimed vide his letter dated 09.07.2024 which the ld. AO has reproduced in the assessment order. Assessee was show caused as to why the penalty proceedings under section 270A(1) read with section 270A(9) may not be initiated for under reporting of income in consequence of misreporting thereof. According to him, since there was no response from the assessee, he p....
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....enunciated in section 270A(9) are as under: a. misrepresentation or suppression of facts; b. failure to record investments in the books of account; c. claim of expenditure not substantiated by any evidence d. recording of any false entry in the books of account e. failure to record any receipt in books of account having a bearing on total income; and f. failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. 7. Ld. Counsel for the assessee strongly asserted that ld. AO has nowhere stated under which of the above six specific instances, case of the ass....