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TMI Blog2022 (12) TMI 1123X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeals filed by the different assessee are against the order passed by the Ld. CIT(Appeals), National Faceless Appeal Centre (in short "NFAC"), Delhi on 12.05.2022 & 24.03.2022 for A.Y. 2015-16. ITA No. 262/Ahd/2022 (A.Y. 2015-16):- 2. The grounds of appeal raised by the assessee are as under: "(1) That on facts, and in law, the learned NFAC has grievously erred in dismissing the appeal as inf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1(1A) of the Income Tax Act was passed on 29.11.2019 and the assessee was considered to be default for non-deduction of TDS under Section 194IA of the Act. The Assessing Officer invoked provision of Section 271C of the Income Tax Act as the assessee was liable to pay the penalty for such default. After issuing notice dated 24.01.2020 the Assessing Officer imposed penalty of Rs. 33,000/- under Sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The Ld. A.R. further submitted that in the co-owners case the CIT(A) therein has deleted the penalty and the said direction should have been followed by the CIT(A) in the present case. 6. The Ld. D.R. relied upon the penalty and the order of the CIT(A). 7. Heard both the parties and perused all the relevant material available on record. It is pertinent to note that the assessee filed applicati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee are as under: "(1) That on facts, and in law, the learned NFAC has grievously erred in dismissing the appeal as infructuous against the levy of penalty of Rs.33,000/- u/s 271C of the Act. (2) That on facts, and in law, the learned NFAC ought to have deleted the penalty as the appellant is entitled to immunity from penalty as the appellant has opted of VSVS in respect of order u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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