TMI Blog2021 (8) TMI 454X X X X Extracts X X X X X X X X Extracts X X X X ..... n. Thus the addition is yet to be finalized. Sub Clause (iii) of Section 271(1)(c) provides mechanism for quantification of penalty. Assessee would be directed to pay a sum in addition to taxes, if any, payable by him, which shall not exceed three times the amount sought to be evaded by reason of concealment of income or furnishing of inaccurate particulars of income. In other words, quantifica ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appeals)-23, New Delhi relating to Assessment Year 2011-12. 2. The relevant facts as culled from the material on records are as under: 3. Assessee is a company stated to be engaged in the business of carrying on infrastructure activities. Assessee filed its return of income for A.Y. 2011-12 on 29.09.2011 declaring loss of ₹ 69,547/-. The case was selected for scrutiny and thereafter as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... penalty u/s. 271(1)(c) of the Act amounting to ₹ 17,53,575/-. 2. The Appellant Company craves leave to add, alter or amend the ground of appeal at a later stage. 4. Before us, Learned AR submitted that while framing the assessment u/s. 143(3), AO had made addition of ₹ 56,75,000/- u/s. 68, being unexplained cash credit. He submitted that against the order of AO, assessee carr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e issue in the present ground is with respect to levy of penalty u/s.271(1)(c) of the Act on the additions made u/s. 68 of the Act by the AO. We find that the Coordinate Bench of Tribunal vide order dated 30.05.2018 has remanded the matter pertaining to the addition made u/s. 68 of the Act to the file of AO for fresh adjudication as per the directions contained therein. Thus the addition is yet to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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