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2022 (11) TMI 224 - AT - Income TaxPenalty u/s 271(1)(c) - furnishing inaccurate particulars of income and concealing the particulars of income - HELD THAT:- CIT(A) has objectively dealt with the contentions of the assessee in respect of issue of complexity of accounts raised by the assessee to substantiate his claim that mistakes were committed by him in maintaining correct accounts. On this aspect, the ld. CIT(A) has noted that assessee was assisted by statutory auditor, authorized representative and accountants and thus he had all the resources available to explain his case and comply with the requirements of the law. CIT-A noted that ld. AO has levied penalties on the final amounts only which remained as confirmed/sustained in the hands of the assessee and not on the initial additions which were made in the assessment. Accordingly, the penalty so imposed is on all those amounts for which either the Co-ordinate Bench of ITAT in the assessment has confirmed the additions or the assessee himself has not preferred any appeal against the order of ld. CIT(A) in respect of the additions. Fact based findings given by the ld. CIT(A) after analyzing the submission filed by the assessee, more particularly where the assessee himself has not preferred any appeal against the order of ld. CIT(A) on certain additions which were confirmed at the First Appellate Stage, we do not find any reason for the interference in the findings so given by the ld. CIT(A) in confirming the penalty levied by the ld. AO u/s. 271(1)(c) - Accordingly, the ground of appeal by the assessee is dismissed.
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