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2019 (7) TMI 298

..... been initiated i.e., whether for concealment of particulars of income or furnishing inaccurate particulars of income. The entire penalty proceedings are, therefore, vitiated and no penalty is leviable. On this score itself similar view is taken by in the case of CIT vs. M/s. SSAs Emerald [2015 (11) TMI 1620 - KARNATAKA HIGH COURT]. This decision is confirmed by the Hon’ble Supreme Court [201 .....

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..... Act, 1961, based on TPO s additions and DRP s direction after making the following additions. (i) TP adjustment ₹ 9,49,21,677/- (ii) Disallowance of depreciation on house property ₹ 26,03,665/-. (iii) Addition on account of notional interest on interest free security deposit ₹ 11,58,822/-. 2.1. The penalty proceedings were initiated. The assessee filed appeal before ITAT which is .....

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..... hed inaccurate particulars of income and concealed the income of ₹ 26,03,665/-. Therefore, penalty proceedings under section 271(1)(c) of the Act have been initiated on this issue. Copy of the show cause notice dated 31.10.2011 is filed in the appeal papers in which the A.O. has mentioned have concealed the particulars of your income or furnished inaccurate particulars of such income. 4.1. T .....

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