2022 (9) TMI 1391

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..... assessee poses a challenge to the consolidated order passed by the CIT(A)-3, Nagpur on 02-05-2017 confirming the penalty of Rs.10,000/- each imposed by the Assessing Officer (AO) u/s.271(1)(b) of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the A.Yrs. 2002-03 to 2008-09. 2. Briefly stated, the facts of the case are that the assessee was subjected to search and asse .....

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..... of the company. The ld. CIT(A) remained unconvinced and affirmed the penalty order. Aggrieved thereby, the assessee has approached the Tribunal. Facts and circumstances for the other appeals under consideration are similar to those for the A.Y. 2002-03 3. I have heard the rival submissions and gone through the relevant material on record. It is seen that the notices, which led to the imposition o .....

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..... t goes without saying that notice u/s.142(1) needs to be properly served on the assessee who is required to submit his reply. If notice is served on a wrong person, who is not authorized to receive the same, it cannot be said that the assessee is at fault in not responding to such notice. It is apparent from the factual panorama recorded above that the notices were issued by the AO on a person who .....

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