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TMI Blog2022 (1) TMI 590X X X X Extracts X X X X X X X X Extracts X X X X ..... vastava, Judicial Member This appeal is preferred by the assessee challenging the order dated 28.08.2021 passed u/s. 250 of the Income Tax Act, 1961 (in short 'the Act') by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'CIT(A)']. 2. The sole issue before us is levy of penalty of Rs. 10,000/- imposed u/s. 27 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ised Representative (AR) drew our attention to order dated 28.05.2021, wherein, the penalty of Rs. 10,000/- u/s. 271(1)(b) of the Act has been imposed on the ground that the assessee had not submitted any submissions/replies in response to the notices and letters issued during the course of assessment proceedings. The Ld. AR drew our attention to Para 4 of the impugned order which reads as under:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re is no non-compliance on the part of the assessee only 13.11.2019 and the assessee immediately as per letter dated 13.11.2019 (copy enclosed) explained to ld. Income Tax Officer, Ward 3(3), Chandigarh as under:- "It is submitted that the said notice has been received today only and for proper reply to all the questions called for will take some time. We appreciate that you are in hurry to deci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed supra that the time given by the ld. Assessing Officer for compliance was merely a symbolic and no reasonable opportunity of being heard was given to the appellant. In view of the above facts and circumstances, it is humbly prayed that penalty levied under Section 271(1)(b) of the Income Tax Act, 1961 may kindly be deleted." 4.1. The Ld. AR submitted that, therefore, the assertion of the Dep ..... X X X X Extracts X X X X X X X X Extracts X X X X
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