ITAT Upholds 100% Penalty on Confirmed Additions Past-Loss Adjustment Irrelevant for 271(1)(c)- Substantial Justice for Delay, No Relief on Merits

Jap Agro Foods Pvt. Ltd. Vs DCIT (ITAT Ahmedabad) ITAT Upholds 100% Penalty on Confirmed Additions Past-Loss Adjustment Irrelevant for 271(1)(c)- Substantial Justice for Delay, No Relief on Merits This appeal was filed by Jap Agro Foods Pvt. Ltd., Vadodara, against the order of CIT(A), National Faceless Appeal Centre (NFAC), Delhi dated 13.10.2023 for AY 2011-12. The issue pertained to the confirmation of penalty imposed u/s 271(1)(c) of the Income-tax Act. The appeal was delayed by 603 days, & therefore, Assessee first sought condonation of the delay supported by an affidavit explaining t...