IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH, AHMEDABAD BEFORE SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER Assessment Year: 2016-17 Deputy Commissioner of Atul Limited, Income Tax, Circle – 1(1)(1), Atul House, Room No.201, 2^nd Floor, G I Patel Marg, Aayakar Bhawan, Vejalpur, Vs. Navjivan S.O., Ahmedabad – 380 015. Ahmedabad – 380 014.

(Gujarat) [PAN – AABCA 2390 M]

(Appellant) (Respondent)

Assessee by Shri Bhavin Marfatia, AR Revenue by Shri Sher Singh, CIT-DR Date of Hearing 09.09.2025 Date of Pronouncement 10.10.2025

O R D E R

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the Revenue against the order of National Faceless Appeal Centre (NFAC), Delhi (in short “the CIT(A)”) dated 12.08.2024 for the Assessment Year (A.Y.) 2016-17 in the penalty proceeding under Section 271G of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2016-17 on 25.11.2016 declaring total income of Rs.301,28,45,510/-. The case was selected for complete scrutiny under CASS. The Assessing Officer noticed that the assessee