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2025 Supreme(Online)(ITAT) 3660

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Brajesh Kumar Singh, AM, Sunil Kumar Singh, JM
Saini Co-operative Tharift and Credit Society Ltd. – Appellant
Versus
Income Tax Officer, Ward-48(1) – Respondent


Advocates:
For the Appellants/Petitioners: Shri V. Rajkumar
For the Respondents: Shri Sanjay Sharma, Sr. DR

Table of Content
1. overview of appeal (Para 1 , 4)
2. facts and arguments presented (Para 2 , 5 , 6)
3. court's observation and conclusion (Para 3 , 7)

ORDER

PER BRAJESH KUMAR SINGH, AM, This appeal by the assessee is directed against the order of the National Faceless Appeal Centre/Ld. Commissioner of Income Tax (Appeals) Delhi, dated 30.08.2024, arising out of penalty order u/s 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’), dated 10.02.2022 for Assessment Year 2013-14 levying penalty of Rs.15,05,000/-.

2. Brief facts of the case:- In the assessment order, the AO noted that the assessee did not file its return of income for the year in question. Based on the information that the assessee had earned interest income of Rs.8,59,514/-, the case of the assessee was reopened by issue of a notice u/s 148 on 06.02.2020. In response to the same, the assessee filed its return of income on 12.03.2020 declaring total income of Rs.1,01,85,390/-. During the course of assessment proceedings, the Assessing Officer held that that the assessee society had claimed exemption u/s 80P(2)(a)(i) of the Act of Rs.50,18,472/- by placing its surplus fund at the disposal of co- opera

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