AI Structured Summary
Not yet generated for this judgment
Judgment
PER SANJAY AWASTHI, ACCOUNTANT MEMBER:
This is a batch of two appeals pertaining to the same assessee and for the sake of convenience, these two appeals are being disposed of through a single order. While ITA 6818 pertains to a penalty u/s 270A of the I.T. Act, 1961 (hereafter “the Act”), ITA 6819 pertains to a penalty u/s 271AA(1) of the Act.
Right at the outset, the Ld. AR mentioned that the quantum matter had already been heard on 19.03.2026 and it was communicated that the matter was to be remanded back to Ld. AO. Indeed, the quantum matters are being adjudicated simultaneously, by this very same combination and they have been remanded back to Ld. AO for fresh assessment order [ITAs No.6798 & 6799/Del/2025 order dated 25.03.2026]. Accordingly, the two penalties (impugned) cannot survive and are directed to be deleted.
However, the Ld. AO would be at liberty to re-initiate penalty proceedings in case the second-round assessment proceedings require him to do so.
In the result, these two appeals are allowed.