Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2016 (7) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2016 (7) TMI 574 - HC - Income TaxPenalty u/s. 271AAA - assessment u/s 1543A pursuant to search - ITAT restricted part penalty - Held that:- We find that both the CIT(A) as well as the Tribunal have rendered a finding of fact that an amount of ₹ 13 lakhs (Rupees thirteen lakhs) and ₹ 23,276/( Rupees Twenty three thousand two hundred seventy six only) alone have not been explained so as to satisfy Section 271AAA(2) of the Act save the above both have held that the other portions of statement made under Section 132(4) stated satisfied. In fact, the Assessing Officer while imposing the penalty has not given any reasons in support of his conclusion that the respondent-assessee does not satisfy Section 271AAA(2) of the Act so as to be excluded from the provisions of Section 271AAA(1) of the Act. Nothing has been shown to us as to why the impugned order of the Tribunal is perverse. The view taken by the Tribunal is a possible view on the facts as found. - No substantial questions of law - Decided against revenue
|