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Judgment
ORDER
PER SATBEER SINGH GODARA, JM
This Revenue’s appeal for assessment year 2013-14, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1082732839(1), dated 18.11.2025 involving proceedings under section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Suffice to say, it transpires at the outset that the Revenue’s sole substantive ground raised in the instant appeal is that the learned CIT(A) has erred in law and on facts in reversing the Assessing Officer’s action levying section 271(1)(c) penalty of Rs.12,16,10,778/- in the assessee’s hands. The same admittedly relates to the latter’s section 80-IA deduction claim disallowance which already stands deleted in the tribunal’s order in its quantum appeal ITA No. 1168/Del/2018 decided on 05.01.2024.
This clinching factual position as per CIT(A)’s detailed discussion in paragraph 7.3 at page 7 has gone unrebutted from the Revenue side. Faced with this situation, we find no merit in the Revenue’s instant sole substantive ground once the assessee has already succeeded in the corresponding quantum proceedings. Learned CIT(A)’s impugned lower appellate findings deleting section 271(1)(c) penalty herein stand affirmed therefore.
This Revenue’s appeal is dismissed.