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2019 (4) TMI 567 - ITAT CUTTACKPenalty u/s 271(1)(c) - Non recording of satisfaction - jurisdictional defect - addition of bogus sundry creditors and agricultural income as income from other sources and on addition of accrued interest on FD’s - HELD THAT:- Admittedly, as noticed from the assessment order, no such satisfaction as contemplated u/s.271(1)(c) have been recorded by the AO while completing the assessment that in which limbs, the issue is following. AO has simply mentioned that “penalty proceedings u/s.271(1)(c) are initiated separately”. See case of V.V.Projects and Investments Pvt Ltd. [2007 (12) TMI 97 - ANDHRA PRADESH HIGH COURT]. - Decided in favour of assessee.
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