TMI Blog2022 (5) TMI 1148X X X X Extracts X X X X X X X X Extracts X X X X ..... curate particulars of income and in the notice the Assessing Officer has not struck down / struck off irrelevant allegation and has made both the allegations simultaneously. Therefore, the issue is covered in favour of the assessee by the judgement of Sahara India Life Insurance Company Ltd. [ 2019 (8) TMI 409 - DELHI HIGH COURT] - Respectfully following the same penalty imposed by the Assessi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder Section 271(1)(c) of the Act on the strength of recent judgement of Hon ble Delhi High Court in the case of Pr. CIT Vs. M/s. Sahara India Life Insurance Company Ltd. 2019 (8) TMI 409 (Del). 3. The ld. AR drew our attention towards copy of the notice under Section 274 read with Section 271(1)(c) of the Act dated 30.12.2016 and submitted that the Assessing Officer has not struck down the irr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ahara India Life Insurance Company Ltd. (supra) the penalty may kindly be cancelled. 4. Replying to the above the ld. Sr. DR strongly supported the penalty as well as the first appellate order. 5. On careful consideration of the rival submissions, I am of the considered opinion that in para Nos. 21 and 22, their Lordships speaking for Hon ble High Court of Delhi, in the identically and simil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a in SLP No.11485 of 2016 by order dated 5th August, 2016. 22. On this issue again this Court is unable to find any error having been committed by the ITAT. No substantial question of law arises. 6. Therefore, facts and circumstances of the present case are quite similar and it is also notable that in the assessment order the Assessing Officer alleges allegation of concealment of particula ..... X X X X Extracts X X X X X X X X Extracts X X X X
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