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TMI Blog2024 (5) TMI 293X X X X Extracts X X X X X X X X Extracts X X X X ..... NT MEMBER : This appeal by the assessee is directed against the order of the ld. CIT (Appeals)/National Faceless Appeal Centre (NFAC) dated 30.12.2023 for the assessment year 2016-17. 2. Grounds of appeal taken by the assessee read as under :- "1. That the order as framed by the Ld. CIT (A) is against law & facts. 2. Because ld. CIT (A) has erred while confirming penalty U/Sec 271(1)(c) on a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ter went upto ITAT, New Delhi and ITAT upheld the disallowance on account of addition u/s 40A(3) of Rs. 2,25,148/-. AO levied the penalty under section 271(1)(c) of the Income-tax Act, 1961 (for short 'the Act') amounting to Rs. 1,72,227/-. Ld. CIT (A) confirmed the penalty order. 4. Against this order, assessee is in appeal before us. We have heard both the parties and perused the records. 5. L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... No costs. Consequently, MP. No.1 of 2007 is closed." Furthermore, ld. Counsel for the assessee submitted that reliance is also placed on the decision of Hon'ble Apex Court in the case of CIT vs. Reliance Petro Products 322 ITR 158 (SC). 6. Per contra, ld. DR for the Revenue relied upon the orders of the authorities below. 7. Upon careful consideration, we find that in this case, assessee does ..... X X X X Extracts X X X X X X X X Extracts X X X X
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