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2022 (12) TMI 782 - ITAT DELHIPenalty u/s 271(1)(c) - AO disallowed 50% of the agricultural income - HELD THAT:- It is a fact on record that though the assessee contested the disallowance before learned Commissioner (Appeals) however, subsequently, it withdrew the appeals. Thus, the aforesaid facts presupposes that the assessee did not have a strong case on merits to contest the disallowance. Disallowance of Swap charges - Commissioner (Appeals) has given a categorical finding that the assessee did not furnish any evidence to establish whether the nature of Swap charges were disclosed before detection by the Assessing Officer. Since, the assessee has failed to appear before us and adduce any evidence or submission to demonstrate that no case of furnishing of inaccurate particulars is made out, it can be safely concluded that the assessee does not have much to say in the matter in its defence. That being the factual position, we do not find any valid reason to interfere with the decision of the Departmental Authorities. Therefore, we uphold imposition of penalty. Disallowance of depreciation on land - In view of specific directions of Commissioner (Appeals), no interference is called for. Accordingly, we uphold the decision of learned Commissioner (Appeals). Appeal of assessee dismissed.
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