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TMI Blog2014 (11) TMI 1208X X X X Extracts X X X X X X X X Extracts X X X X ..... DR ORDER PER DIVA SINGH, JM These seven appeals have been filed by the assessee against the separate order of the CIT(A) who has confirmed the penalty imposed u/s 271(1)(b) in 2005-06 to 2011-12 assessment years. All these appeals are being decided by a common order as facts, circumstances and arguments of the parties in regard to the specific default noted by the AO remain the same. The recor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 000/- u/s 271(1)(b) was imposed for each of the years. The said order was confirmed in appeal by the CIT(A). 2. The Ld. AR relying upon various orders of the Tribunal contended that on similar facts and circumstances, different Benches of the ITAT in connected cases have quashed the penalty imposed. It was his submission that in the facts of the present case the assessments as in the connected ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al & Diagnostic Pvt. Ltd. 4661, 4662, 4663 & 4664/Del/2013 G 14.02.2014 Sanya Hospitality Pvt. Ltd. 4665, 4666, 4667, 4668, 4669, 4670/Del/2013 G 14.02.2014 Dhruv Madan 4678, 4679, 4680, 4681, 4682 & 4683/Del/2013 B 24.06.2014 Chhavi Dass 4684, 4685, 4686, 4687, 4688, 4689 4690/Del/2013 B 25.06.2014 2.1. The Ld. CIT DR placed reliance upon the impugned order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case where assessments were made u/s 143(3) and not u/s 144, it means that subsequent compliance in assessment proceedings was considered as good compliance and the defaults committed earlier were ignored by the AO which view has been followed by Co-ordinate Benches of the ITAT in the orders relied upon by the assessee and brought to our notice. Considering the peculiar facts and circumstan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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