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Judgment
All the four appeals filed by the assessee against the levy of penalty u/s 271(1)(c) of the Act for AY 2013-14, 270A for AY 2017-18, 271AAB for AY 2018-19 and AY 2019-20.
At the outset, it is submitted that appeals against the assessment orders for all the assessment years before us have already been decided where the Co-ordinate Bench of tribunal vide its order dated 30.01.2026 in ITA Nos. 2606, 2632, 2728 and 2729/Del/2023 and C.O. No.133, 132, 137 and 138/Del/2023 for AY 2013-14, AY 2017-18, AY 2018-19 and AY 2019-20 and Cross objections filed by the assessee were allowed on the issue of invalid and mechanical approval u/s 153D of the Act and the orders so framed u/s 153A/143(3) were quashed for all the four assessment years.
Since, the assessment orders wherein present penalty proceedings were initiated stood quashed, thus no penalty could be levied. In the light of above, the penalty orders for all the four assessment year are hereby quashed. All the grounds of appeal are allowed.
In the result, all the four appeals of the assessee in ITA Nos. 6299 to 6302/Del/2025 for AY 2013-14, 2017-18, 2018-19 and 2019-20 are allowed.