2025 (4) TMI 2166

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....CIT(A)-11, Pune erred in confirming the levy of penalty by the AO u/s 270A in respect of income declared by the appellant in survey which was offered to tax in his return of income filed u/s 139(1) not accepting the submission of the appellant that: a. There being no difference in the returned income and assessed income, levy of penalty for under reporting of income inconsequence of misreporting is incorrect. b. No penal proceedings having been issued at the time of assessment, initiation and levy of such penalty subsequent to the CIT(A)'s order is incorrect. The appellant prays that, the AO be directed delete the penalty. The appellant craves leave to add to, amend, alter, delete or modify all or an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....een initiated by Assessing Officer. We have scanned and reproduced the order giving effect as under : 4.1 Thus, it can be seen from the scanned copy that there is no mention of initiation of penalty u/s.270A of the Act. However, there is a small error in the said order i.e.in one place it was mentioned as "A.Y.2010-11", however at all other placed the assessment year mentioned is "A.Y.2019-20". We have also cross checked the total income and the additions, with the assessment order and the figures mentioned in the assessment order for A.Y.2019-20 matches with the order giving effect to the order of CIT(A)-11, Pune dated 20.01.2023. Therefore, the order before us is for A.Y.2019-20. Ld.DR has also not taken any objection. 4.2 Thus, it ....