आदेश/ORDER 

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the CIT(A)-25, Mumbai, dated 10.10.2016, which in turn arises from the order passed by the A.O under Sec. 271(1)(c) of the Income-tax Act, 1961 (for short „I.T Act‟), dated 19.02.2014 for Assessment Year 2009-10. The assessee assailing the order of the CIT(A) has raised before us the following grounds of appeal:

“1. The Ld. CIT(A) erred in law and in fact upholding the penalty of Rs. 1,53,16,970/- under section 271(1)(c) of the Income-tax Act, 1961. The same is contrary to the various well settled judicial pronouncements in favour of the appellant and should be deleted.

2. The Ld. CIT(A) erred in law and in fact that penalty proceedings is different from assessment proceedings as decided under various judicial and ignored record produce before it and uphold penalty levied only based on assessment proceedings.

3. The Ld. CIT(A) erred in law and in fact while ignoring ratio laid down by jurisdictional High Court and Tribunal having similar facts and question and relying on decision of non-jurisdictional court having different fact and issues.

4. The Ld. CIT(A) erred in law in n