IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’, NEW DELHI BEFORE SH. M. BALAGANESH, ACCOUNTANT MEMBER AND SH. SUDHIR KUMAR, JUDICIAL MEMBER ITA No.4807/Del/2025 Assessment Year: 2014-15 M/s ZF STERLING GEAR Vs DCIT Central Circle-15, (INDIA) LIMITED, NEW DELHI GAT 1242 1244 VADHU ROOM NO. 245, DGIT BUDRUK TAKUKA SHIRUR (SYSTEMS) ARA KOREGAON BHIMA, PUNE, CENTRE, GROUND MAHARASHTARA FLOOR E-2 (PAN: AAACZ0549G) JHANDEWALAN EXTENSION, NEW DELHI (APPELLANT) (RESPONDENT)

Appellant by Shri Shivam Garg, Adv. & Shri Mihir Kaushik, Adv.

Respondent by Shri Om Prakash, Sr. DR.

Date of hearing: 12/03/2026 Date of Pronouncement: 27/03/2026

ORDER

PER SUDHIR KUMAR, JM:

This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-11, Pune, hereinafter referred to as “(Ld.CIT(A)”], vide order dated 11.01.2019 pertaining to A.Y. 2014-15 and arises out of the penalty order dated 29-11-2023 passed by the Assessing Officer under Section 271(1)(c) of the Income Tax Act, 1961 [hereinafter referred as ‘the Act’]. Assessee has raised as many as 13 grounds of appeal, however, he argued only legal ground no. 4, which reads as under:-

“That the Ld. CIT(A) erred in sustain