IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER AND SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER I.T.A. No. 89/Ran/2022 (Assessment Year-2015-16)

(Virtual Hearing)

Alliance Dealers Private Limited, D.C.I.T., CA Akshay Ringasia, Suite No. 3, 2nd Central Circle, Vs.

Floor, Aviskar Bumra Enclave, Diagonal Jamshedpur.

Road, Bistupur, Jamshedpur-831001.

PAN No. AAHCA 2615 B Appellant/ Assessee Respondent/ Revenue Assessee represented by Shri Akshay Ringasia, C.A.

Department represented by Shri Khubchand T. Pandya, Sr.DR Date of hearing 10/03/2025 Date of pronouncement 10/03/2025

O R D E R

PER: BENCH

1. This appeal by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), Patna-3, [in short, the ld. CIT(A)] dated 26/07/2022 for the Assessment Year (AY) 2015-16. In this appeal, the assessee has raised following grounds of appeal:

"1. That under the facts and circumstances of the case, no penalty u/s 271(1)(c)

should had been levied, hence, the impugned order levying penalty of Rs.

2,62,650/-needstobequashed.

2. ThattheveryinitiationofpenaltyisbadinlawastheLd.AOhasfailedtorecord a proper or transparent satis