(1.) THE present appeal has been filed by the Revenue against the order dated April 5, 2007, passed by the Income Tax Appellate Tribunal, Delhi Bench "H", New Delhi in I. T. A. No. 175/D/2006 in the case of the respondent -assessee for the assessment year 1993 -94 raising the following substantial questions of law:
(2.) A brief facts giving rise to this appeal are as under:
(3.) THE Assessing Officer initiated penal proceedings under Section 271(1)(c) and in those penalty proceedings, the assessee was granted an opportunity to explain as to why penalty orders should not be passed on the points of additions which were finally upheld by the Tribunal. The assessee vide his letter dated April 18, 2005, submitted that they had neither concealed nor submitted any inaccurate particulars and it was requested that the penalty proceedings may be dropped. However, the Assistant Commissioner of Income Tax, Range -I, Faridabad vide his order dated April 28, 2005, passed the penalty order against the respondent -assessee. The relevant part of the order is reproduced as under: