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2025 (3) TMI 212

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....ssee is before this Appellate Tribunal, feeling aggrieved by order dated 15.10.2024, passed by Learned CIT(A), NFAC, Delhi. The matter pertains to the assessment year 2014-15. Vide impugned order, penalty imposed by the Assessing Officer u/s 271E of the Income Tax Act, 1961 (in short "the Act") has been upheld. The Assessing Officer imposed penalty of Rs. 24,988/-, finding that the assessee had....

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....initiated against the assessee, and as such, the penalty order and the impugned order deserve to be set aside. In support of his contention, Ld. AR has relied on decision in Commissioner of Income Tax v. Jai Laxmi Rice Mills Ambala City, 64 taxmann.com 75, Supreme Court (2015). 4. On the other hand, Ld. DR for the department has submitted that for the reasons recorded by Learned CIT(A), present ....

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....e limit prescribed u/s 44AD of the Income Tax Act 1961. Hence penalty proceedings u/s 2718 of the Income Tax Act 1961 are being initiated separately. In this case the turnover of the assessee is Rs. 1,61,11,776/-which is above 1 crore. Hence the assessee is liable to maintain the books of accounts and audit of accounts of certain persons carrying on business or profession as per u/s 44AA/44AB of....

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....d for concealment and furnishing of inaccurate particulars in respect of income. Notice u/s 274 r.w 271(1)(c) issued. Necessary forms and demand notice issued." 6. As is available from the relevant portions extracted above, from the assessment order pertaining to quantum proceedings, it is obvious that the Assessing Officer nowhere recorded satisfaction that it was a case of violation of provisio....