The CIT(A) noted that even after the additions finally made by the AO, the assessee was subjected to pay taxes u/s 115JB of the Act. Further under Circular No. 25 of 2015, dated 31.12.2015 ([2016] 380 ITR (St.) 34), in the aforesaid circumstances, penalty u/s 271(1)(c) of the Act was not attracted in respect of the additions or disallowances made under the normal provisions of the Act. Held, there was no reason to interfere with the order of the CIT(A). (AY.2012-13, 2013-14)
Dy. CIT v. Havells India Ltd. (2023) 103 ITR 16 (SN)(Delhi)(Trib)
S. 271(1)(c): Penalty —Concealment-CIT (A) observed that assessee was subjected to pay taxes u/s 115JB,even after taking into consideration additions made in assessment order-held, with reference to cbdt circular no. 25 of 2015, dated 31.12.2015 penalty was not leviable-Order upheld. [S.115JB]