TMI Blog2019 (4) TMI 703X X X X Extracts X X X X X X X X Extracts X X X X ..... O is at liberty to initiate the penalty proceedings, if any, after passing fresh assessment order. Consequently appeal filed by the revenue as well as Cross Objection filed by the assessee are allowed for statistical purposes. - ITA No.3369/Del./2016, C.O. No.269/Del./2016 - - - Dated:- 10-4-2019 - Shri R.K. Panda, Accountant Member And Shri Kuldip Singh, Judicial Member For the Assessee : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erred in law in deleting the penalty levied by the AO u/s 271(1)(c) amounting to ₹ 1,46,566,380/- ignoring the fact that the assessee has made wrong claim for deduction under the provision of Income Tax Act, 1961. 2. The Appellant craves to be allowed to add any fresh ground(s) of appeal and/or delete or amend any of the ground(s) of appeal. 3. Cross objector PTC India Ltd. hereby ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f income. 4.That in the absence of specific charge, the levying of penalty under section 271(1)(c) is illegal and without jurisdiction. 5.That the respondent reserves the right to add/amend/ alter the grounds of Cross Objection. 4. Briefly stated that facts necessary for adjudication of the controversy at hand are : on the basis of completed assessment u/s 143(3) at the income of &# ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l. Feeling aggrieved revenue as well as assessee have come up before the Tribunal by way of filing present appeal as well as Cross Objections. 6. We have heard the ld. Authorized Representatives of the parties to the appeal, gone through the documents relied upon and orders passed by the revenue authorities below in the light of the facts and circumstances of the case. 7. At the very outset, ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
