TMI Blog2019 (6) TMI 789X X X X Extracts X X X X X X X X Extracts X X X X ..... eal of the Assessee is allowed for statistical purposes. - ITA NO. 642/Chd/2018 - - - Dated:- 14-6-2019 - Shri. N.K.Saini, VP And Shri, Sanjay Garg, JM For the Assessee : Shri. N.K. Saini, ITR For the Revenue : Sh. Mudit Srivastava, Sr. DR ORDER PER N.K. SAINI, VICE PRESIDENT This is an appeal by the Assessee against the order dt. 10/04/2018 of Ld. CIT(A)-, Patiala. 2. In the present appeal Assessee has raised the following grounds: 1. The learned CIT(A) has erred in facts and law in confirming the penalty under section 271(1)(c) levied by the AO at ₹ 69,72,671/- without considering his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nishing of inaccurate particulars of income . Since the order passed is bad in law it deserves to be quashed. 6. The Learned C1T(A) has confirmed the levying of penalty without affording adequate opportunity of being heard. The order is liable to be set aside. 7. In any case the learned assessing officer has erred in levying the penalty under section 271(1)(c ) at 300% of the tax sought to be evaded without bringing on record any special or extraordinary circumstances for levying maximum penalty. 8. The appellant craves leave for any addition, deletion or amendment in the grounds of appeal on or before disposal of appeal. 3. The facts of the case in brie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y following the order of Hon'ble ITAT mentioned supra, the alternate submission of the Appellant which were not offered by him during proceedings in the quantum assessment proceedings were examined and as mentioned in para 3.1 supra a number of opportunities were given to the appellant. Finally after service of notice by affixture, the AR appeared on behalf of the appellant. Qua these alternate submissions, the appellant has produced copies of three separate bank accounts, a loan account with Bank of Baroda relating to M/s Sai Cold Storage Pvt. Ltd., a current account relating to M/s Sai Cold Storage Pvt. Ltd with Oriental Bank of Commerce and a Savings Bank account of Shri Ashwani Kumar himself in Oriental Bank of commerce (the impugne ..... X X X X Extracts X X X X X X X X Extracts X X X X
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