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Stanford Laboratories Pvt. Ltd. vs DCIT

Case No: ITA No.5296/Del/2024
Court: Income Tax Appellate Tribunal, Delhi “G” Bench, New Delhi
Date: 3/20/2025

Parties Involved

appellantStanford Laboratories Pvt. Ltd.
respondentDCIT Circle-22(2), New Delhi

Facts Summary

The appeal has been filed by Stanford Laboratories Pvt. Ltd. against the First Appellate order dated 24.09.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, confirming the penalty imposed by the Assessing Officer under section 271(1)(c) of the Income Tax Act, 1961 amounting to INR 1,39,44,461/-. The penalty appeal was filed belatedly by 538 days. The assessee argued that the penalty order was served at the old address, whereas the assessee had shifted to a new address. The penalty order remained unserved due to this change of address. The assessee obtained a certified copy of the penalty order on 13.05.2022 and filed the appeal thereafter. The assessee contends that there was sufficient cause for the delay due to bonafide reasons.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the delay in filing the appeal before the CIT(A) should be condoned?
  • 2. Whether the penalty imposed under section 271(1)(c) is sustainable?

Judgment Outcome

Decided in favour of Assessee.

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