9911796707
TMI Blog2022 (9) TMI 75X X X X Extracts X X X X X X X X Extracts X X X X ..... , AM : This appeal filed by the assessee is directed against the order dated 17.06.2019 of the Commissioner of Income Tax (Appeals)-31, New Delhi relating to Assessment Year 2014-15. 2. Brief facts of the case as culled out from the material on record are as under :- 3. AO has noted that assessee had failed to issue TDS certificate to the deductee within the prescribed time u/s 203 of the Act ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble opportunity of being heard in clear violation of the principles of natural justice. 3. On the facts and circumstance of the case, the Learned CIT(A) has erred both on facts and in laws in confirming the penalty ofRs.11,84,599/-levied by JCIT under section 272A(2)(g) of the Act. 4. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in violation of principle of natural justice. 7. On the facts and circumstances of the case, the learned CIT(A) has erred, both on facts and in law, in confirming penalty despite the fact that there is no contumacious conduct on the part of the assessee for the delay in issuing of TDS certificates. 8. The appellant craves leave to add, amend, or alter any of the grounds of appeal. 5. Befor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act mandate the CIT(A) to state the points in dispute and thereafter assign the reasons in support of his conclusion. We are of the view that by dismissing the appeal without considering the issue on merits, Learned CIT(A) has failed to follow the mandate required in Sub Section (6) of Section 250 of the Act. Further it is also a well settled principle of natural justice that sufficient opportunit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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