9911796707
TMI Blog2025 (2) TMI 610X X X X Extracts X X X X X X X X Extracts X X X X ..... J M: This appeal has been filed by the assessee, challenging the order of the learned Commissioner of Income Tax (Appeals), Delhi ('ld. CIT(A)' for short), National Faceless Appeal Centre ('NFAC' for short) passed u/s.250 of the Income Tax Act, 1961 ('the Act'), pertaining to the Assessment Year ('A.Y.' for short) 2017-18. 2. The assessee has challenged the penalty of Rs. 50,000/-, u/s. 272 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s. 142(1) on several dates and then passed the assessment order u/s. 144 of the Act, dated 03.12.2019, being the best judgement assessment, where the ld. AO determined the total income at Rs. 11,89,370/-, after making an addition u/s. 69A of the Act, towards cash deposits made in the Central Bank of India and Department of Posts. The ld. AO also initiated penalty proceedings u/s. 272A(1)(d) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tory notices could not be served on the assessee. The ld. AR reiterated that the assessee has not been negligent or non-compliance of the notice was not wanton and prayed that the penalty be deleted. 8. The learned Departmental Representative ('ld. DR' for short) on the other hand relied on the orders of the lower authorities. 9. We have heard the rival submissions and perused the materials avai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee in his reply has stated that he is neither cognizant of law and its intricacies and had submitted the details of bank statements after which the ld. AO passed the assessment order and the penalty order thereafter. It is also observed that the ld. CIT(A) in the quantum appeal has upheld the addition made by the ld. AO for which the ld. AR for the assessee submitted that the assessee has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... whether its implementation is also the same with all people belonging to different stratum of society who are not equal in terms of education, income or social status. We are aware of various decisions of the Hon'ble High Courts and Hon'ble Apex Court which has reiterated that the revenue cannot take undue advantage of the inability of the assessee and taking cognizance of the same, we deem it fi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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