IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘B’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER A.Ys. 2019-20 & 2021-22 PDAisNtr:i cAtA CAoAopPe8r8a3ti3vHe Bank Limited, vs. Addl / JDIT (I & CI)

Civil Lines Kachehri, Shahjahanpur (Appellant) (Respondent)

Assessee by: Sh. B.P. Yadav, Adv Revenue by: Sh. R.R.N. Shukla, Addl CIT DR Date of hearing: 09.12.2025 Date of pro nouncement: O R D3 0E. 0R1 .2026 PER NIKHIL CHOUDHARY, A.M.:

These two appeals have been filed by the assessee against the orders of the ld. CIT(A), NFAC for the Assessment Years 2019-20 and 2021-22 wherein the ld. CIT(A), NFAC has confirmed the penalty levied under section 271FA of the Income Tax Act, amounting to Rs. 9,73,000/- for the Assessment Year 2019-20 and under section 271FAA amounting to Rs. 50,000/- for the Assessment Year 2021-22 that was levied by the ld. AO for failure to file statement of financial transactions / furnishing of incorrect information in the statement of financial transactions. AT.hYe. 2 g0r1o9u-n2d0s of appeal are as under:-

“1.1 The Learned Commissioner of Income Tax (Appeals), NFAC, Delhi (hereinafter referred to as the "Ld. CIT(