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TMI Blog2022 (12) TMI 502X X X X Extracts X X X X X X X X Extracts X X X X ..... eenivasan (Addl. CIT) -Ld. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2011-12 arises out of the order of learned Commissioner of Income Tax (Appeals)-10, Chennai [CIT(A)] dated 28-09-2018 confirming levy of penalty u/s. 271(1)(c) by Ld. AO vide order dated 30.05.2017. Though the assessee has raised multiple grounds of appeal, howev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cs. The assessee was saddled with other small additions of difference of pension amount and interest on bank account. The order was subjected to appeal before first appellate authority wherein Ld. CIT(A) granted partial relief to the assessee. The deduction claimed u/s 54EC was confirmed and deduction claimed u/s 54F was partly allowed. The order attained finality by dismissal of further appeals b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of difference in pension and interest on bank account was to be confirmed. Aggrieved, the assessee is in further appeal before us. 5. From the facts, it emerges that the assessee considered the sale transactions as three sale transactions and made three separate investments in REC bonds to claim deduction u/s 54EC. The assessee accordingly claimed deduction of aggregate investment. The assessee f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect fact, falsity and untruth. Therefore, it is not a fit case for imposition of penalty. The other two additions are small additions which, in any way, is not a fit case for levy of penalty considering the fact that the assessee is a senior citizen and may have missed out to compute pension and interest correctly. Therefore, we by deleting the impugned penalty, we allow the appeal. 6. The appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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