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2023 (1) TMI 1373 - ITAT DELHIPenalty u/s 271(1)(c) - Assessee argued AO has failed to point out the exact head/limb under which the penalty is levied and has claimed that it made the penalty invalid - HELD THAT:- We find that the above ground has not been raised before any of the authorities below nor any evidence in the said notice, without ticking off the relevant limb, has been filed before us. In these circumstances, in the interest of justice, we remit the issue to the file of the CIT(A). CIT(A) is directed to examine the assessee’s claim that the relevant limb in the penalty notice about the charge against the assessee was not specified. After examining the same and the factual veracity thereof, the ld.CIT(A) shall pass an order as per law. Needless to add, the assessee should be granted adequate opportunity of being heard.
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