ORDER

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:-

This appeal by the assessee is preferred against the order of the NFAC, Delhi dated 20.12.2022 for A.Y 2017-18.

2. The assessee has raised the following grounds of appeal:

“1. On the facts and circumstances of the case, the order passed by the learned Commissioner Income Tax (Appeals), National Faceless Appeal Centre (CIT(A), NFAC)) is bad, both in the eye of law and on the facts.

2 On the facts and circumstances of the case, the learned CIT(A), NFAC has erred both on fact and in law, in confirming the action of the AO (JCIT, Range-35) levying the penalty of Rs. 33,60,000/- invoking section 271D of the Income Tax Act.

3. On the facts and circumstances of the case, the learned CIT(A), NFAC has erred both on fact and in law, in passing the order by wrongly holding that the assessee has violated the provisions of section 269ST of the Income Tax Act and thus liable for penalty under section 271DA of the Act by grossly ignoring the fact that AO has levied the penalty under section 271D in respect of violation of the provisions of section 269SS of the Income Tax Act.

4. On the facts and circumstances of the case, the learned CIT(A), NFAC has erred b