TMI Blog2018 (11) TMI 1605X X X X Extracts X X X X X X X X Extracts X X X X ..... imb, he is levying the penalty and it is trite that penalty cannot be levied for twin charges until and unless the satisfaction recorded under both the limbs separately and followed with correct notice u/s 274 of the Act, specifying exact limbs, because the penalty for furnishing of inaccurate particulars and concealment of particulars of income are all altogether mutually different connotation wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sel of the assessee submitted that although he has raised as much as seven grounds of appeal, however, the case on legal aspects, squarely covered by various judgments of different High Courts and specifically the latest order passed by the Amritsar Bench in Third Member Case in case of HPCL Mittal Energy Ltd., Bathinda vs. Addl. CIT, Circle-1, Bathinda in ITA Nos.554 555(Asr)/2014 510 556(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... part deletion of addition ₹ 13,84,841/- the department filed the appeals before the Hon ble ITAT, Amritsar, the coordination bench vide order dated 15.06.2016 had restricted the addition to ₹ 521,323/ in the appeal of the Assessee and dismissed the appeal of the department due to low monetary limit as per CBDT Circular applicable at that time . In the assessment order, the Assessin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 274 of the Act, specifying exact limbs, because the penalty for furnishing of inaccurate particulars and concealment of particulars of income are all altogether mutually different connotation which is settled by the various Courts, hence, we do not have any hesitation to delete the penalty being illegal and unjustified. Consequently, the order impugned herein passed by the Ld. CIT(A) is liable to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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